News & Analysis as of November 17, 2024

FinCEN › Today's Popular Updates › AML/CFT

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

TD Bank gets $1.3 Billion Penalty from FinCEN

Foodman CPAs & Advisors on 11/5/2024

On 10/10/24, FinCEN assessed a record $1.3 billion penalty against TD Bank for BSA violations. This unprecedented penalty should function as a cautionary message and a warning to all financial institutions. All financial...more

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

ArentFox Schiff on 11/4/2024

On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on 10/24/2024

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

FinCEN Issues Final Rule: Implications for Real Estate Money Laundering

Kohn, Kohn & Colapinto LLP on 10/18/2024

The Financial Crimes Enforcement Network (FinCEN), a bureau within the United States Department of Treasury, has issued a new investment advisor rule to protect residential real estate from illicit finance, such as money...more

FinCEN Adopts Final Rule Extending Anti-Money Laundering Compliance Program Requirements to Certain Investment Advisers

Vedder Price on 10/15/2024

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule (Final Rule) that adds registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to the definition of “financial...more

FinCEN Withdraws Designation of ABLV Bank as Foreign Financial Institution “Of Primary Money Laundering Concern”

Ballard Spahr LLP on 10/14/2024

A Gesture Providing Limited Solace to a Now-Defunct Bank - Six years ago, in early 2018, we blogged about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (“FinCEN’s”) designation of ABLV Bank, AS...more

FinCEN Finalizes Rule Requiring AML/CFT Programs for Registered Investment Advisers and Exempt Reporting Advisers

Wilson Sonsini Goodrich & Rosati on 10/4/2024

On September 4, 2024, the U.S Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule that expands the definition of “financial institution” to include Registered Investment Advisers...more

FinCEN Final New Rules Close Loopholes in U.S. Financial System

Foodman CPAs & Advisors on 9/27/2024

On August 28, 2024, FinCEN Final New Rules were published that address vulnerabilities in the U.S. financial system and are part of an on going effort to combat illicit finance and protect U.S. national security, as well as...more

FinCEN Issues Final Rule Requiring Investment Advisers to Establish Anti-Money Laundering Programs

Cooley LLP on 9/23/2024

On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule that expressly includes certain investment advisers in the definition of a “financial institution”...more

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on 9/19/2024

Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

FinCEN’s Final Rule on Anti-Money Laundering for Residential Real Estate Transfers

King & Spalding on 9/12/2024

On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule under the Bank Secrecy Act (“BSA”) requiring certain persons involved in real estate closings and settlements to report and maintain...more

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

Foley Hoag LLP on 9/10/2024

On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

FinCEN Issues Final Rule Expanding Anti-Money Laundering/ Countering the Financing of Terrorism Requirements for Investment...

King & Spalding on 9/10/2024

On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

Holland & Knight LLP on 9/6/2024

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more

Investment Advisers Prepare: The BSA is Here

Lowenstein Sandler LLP on 9/3/2024

On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more

What Is an “Effective AML/CFT Compliance Program”?

Perkins Coie on 8/23/2024

The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

FinCEN Proposes Rule to Enhance AML/CFT Programs Across Industries

Ballard Spahr LLP on 7/26/2024

FinCEN’s recent preliminary rulemaking aims to enhance and modernize regulations with requirements and priorities that affect a broad range of “financial institutions” across industries—but lacks concrete guidance on...more

FinCEN Issues Proposed Rule to Strengthen, Modernize AML/CFT Programs

Cooley LLP on 7/25/2024

In late June 2024, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule to modernize the anti-money laundering (AML) and countering the financing of terrorism (CFT) program...more

FinCEN Proposes Changes to Anti-Money Laundering Program Requirements for Financial Institutions: 5 Things to Know

Orrick, Herrington & Sutcliffe LLP on 7/24/2024

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule to counter money laundering and the financing of terrorism that would add significant compliance requirements for financial...more

FinCEN Proposes Rule To Strengthen US Anti-Money Laundering and Countering the Financing of Terrorism Programs

Skadden, Arps, Slate, Meagher & Flom LLP on 7/17/2024

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule (the Proposed Rule) to implement certain aspects of the Anti-Money Laundering Act of 2020 (the AML Act), which updated the...more

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

Ballard Spahr LLP on 7/16/2024

On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

FinCEN & the SEC: Will the Real RIA and ERA Customers Please Stand Up?

Morrison & Foerster LLP on 7/8/2024

On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more

FinCEN Issues Proposed Rule to Enhance Financial Institutions’ AML/CFT Programs

Vedder Price on 7/3/2024

On June 28, 2024, in an effort to bolster financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs, the U.S. Department of the Treasury’s Financial Crimes Enforcement...more

AML/CFT Rules for Investment Advisers

K2 Integrity on 6/18/2024

On 12 June 2024, K2 Integrity and Schulte Roth & Zabel hosted a webinar discussing new regulatory obligations anticipated under proposed rules for investment advisers (IAs), timelines for finalization and compliance, and how...more

Request for Comments on FinCEN and SEC rule on CIP

King & Spalding on 5/24/2024

The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

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FinCEN › Today's Popular Updates › AML/CFT

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