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No-Action Letters Financial Institutions AML/CFT

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Pursues Its Next Steps, Posting its Priorities and Pondering a No-Action Process

The Financial Crimes Enforcement Network (FinCEN) has completed two of its early benchmark obligations arising out of the recently passed Anti-Money Laundering Act of 2020 (the “AML Act”)... First, pursuant to the AML Act,...more

WilmerHale

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

WilmerHale on

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Ballard Spahr LLP

Proposed AML Reforms Aim to Enhance and Modernize AML/CFT Enforcement

Ballard Spahr LLP on

Second Post in a Two-Post Series on the ILLICIT CASH Act - A discussion draft of legislation recently introduced in the Senate, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal...more

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