All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
Starting January 1, 2026, the New York LLC Transparency Act (the “Act”) will require limited liability companies (LLCs) formed or authorized to do business in the State of New York to disclose information to the NY Department...more
On January 29, 2024, the U.S. Department of Commerce’s (Department) Bureau of Industry and Security issued a notice of proposed rulemaking (Proposed Rule) that proposes a new Customer Identification Program (CIP) and other...more
ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more
In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more
As we begin the annual ritual of making our personal New Year’s resolutions, it’s a great time for secondaries market participants to do the same. As we gear up for what is expected to be an active 2024, here are our...more
Many entities across the United States are about to have increased reporting requirements starting January 1, 2024. After a long anticipated-wait, FinCEN, the Financial Crimes Enforcement Network, issued a final rule on the...more
Although the Corporate Transparency Act (CTA”) was adopted in 2021, implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) established regulations. The deadline,...more
企業透明性法（以下「法」）は2021年に採択されたが、財務省の金融犯罪取締ネットワーク（以下「FinCEN」）が規制を設ける間、施行が遅れていました。しかし、その遵守期限は間近に迫っています。2024年1月1日以降に設立される報告対象会社は、設立後30日以内に報告書を提出する必要があります。2023年末時点ですでに存在する報告対象会社は、2024年末までに最初の報告を行う必要があります。...more
Although the Corporate Transparency Act (the “Act”) was adopted in 2021, implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) established regulations. The...more
Privy Council rules against extension of the Quincecare duty - Does a bank owe a duty of care to a person who is the beneficial owner of funds held in the account of a customer of the bank and who has been defrauded by...more
Executive Summary - The U.S. Congress recently passed the Corporate Transparency Act (“CTA”) as part of the 2021 National Defense Authorization Act. The CTA requires certain corporations, limited liability companies and...more
The Corporate Transparency Act (CTA), part of the 2021 National Defense Authorization Act enacted into law on January 1, 2021, will impose new beneficial ownership reporting requirements on many companies. The stated purposes...more
Effective as of January 1, 2021, Congress enacted - over President Trump's veto - the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (the "NDAA"). As with any U.S. defense bill, the NDAA...more
In the government’s continuing effort to combat money-laundering, Congress recently passed the Corporate Transparency Act (CTA) to require private companies to disclose their “beneficial owners” to the U.S. Department of the...more
I. Background - Sweden’s financial supervisory authority (“SFSA”) recently fined Swedbank AB a record 4 billion Swedish kronor (approximately $386 million) for deficiencies in its anti-money laundering (“AML”) processes...more
FinCEN Cites Low Risk of Money Laundering and High Regulatory Burden of Rule - On September 7, 2018, the Financial Crimes Enforcement Network (“FinCEN”) issued permanent exceptive relief (“Relief”) to the Beneficial...more
France’s transposition of European Directive 2015/849 dated 20 May 2015 on money laundering is now in effect, with a compliance deadline of 1 April 2018. The provisions of Ordinance no. 2016-1635 of 1 December 2016...more
This week, the U.S. Senate Committee on the Judiciary and the U.S. Senate Committee on Banking, Housing and Urban Affairs held hearings focused in part on Anti-Money Laundering (“AML”) and the Bank Secrecy Act (“BSA”)....more
Last week, the Financial Action Task Force (“FATF”) issued a report concluding that Mexico needs to “step up efforts in pursuing money launderers.” ...more
Global companies should implement an AML program and KYC practices that follow the general outline for best practices, though it does not need to be as rigorous as a financial institution. For most companies, AML risks can...more
In May 2016, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its final rule on Customer Due Diligence (CDD) Requirements for Financial Institutions. ...more
On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more
Anti-money laundering professionals are in for a rude awakening. Know Your Customer or KYC requirements are currently kicking up a notch, and will be even more dramatic when the new FinCEN beneficial ownership regulations...more
Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more