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
In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more
Durante la Conferencia Anual contra el Lavado de Dinero de FIBA (“Financial and International Business Association”) celebrada el 18 al 21 de marzo de 2024 en Miami, Florida, la Directora Gacki de FinCEN discutió las...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more
On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more
On February 7, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking on certain US residential real estate transactions (“2024 NPRM”). The 2024 NPRM...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more
On Feb. 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM)1 in response to illicit finance risks identified in the U.S. residential real estate...more
CTA Denial #3: “My industry’s lobbyists would never allow such a law to get passed.” Lobbyists had staved off attempts to implement the CTA, and its predecessor bills, for decades....more
Beginning January 1, 2024, domestic entities and foreign entities registered to do business in the United States will need to comply with new information reporting requirements relating to their owners, officers, and...more
The U.S. government just averted a government shutdown this past Saturday (or at least punted for another 45 days). In the last three weeks all signals from the Financial Crimes Enforcement Network (“FinCEN”) suggests the...more
On January 1, 2024, the Corporate Transparency Act (the “Act” or the “CTA”) will go into effect. It is expected to impact approximately 32.6 million small and medium-sized businesses in unregulated industries in its first...more
Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
FinCEN Proposes the Second Installment to the Corporate Transparency Act - On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the "Notice") in relation to the...more
In December 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting requirements of...more
FinCEN ha estado ocupada en la búsqueda de combatir la corrupción, como lo demuestra la emisión consecutiva de Avisos de Propuesta de Reglamentación (“NPRMs”). El 6/12/21, emitieron el (Proceso regulatorio para los nuevos...more
FinCEN has been busy in the quest to fight corruption as evidenced by back-to-back issuance of Notices of Proposed Rulemaking (NPRMs). On 12/6/21, they issued the (Regulatory Process for New Real Estate Sector Reporting...more
The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, published a Notice of Proposed Rulemaking (the “Proposed Rules”) on December 8, 2021 in the Federal Register. The...more
On January 1, 2021, Congress enacted the National Defense Authorization Act of 2021. As part of this legislation, Congress set out new Beneficial Ownership Information Reporting Requirements (BOI Reporting Requirements) for...more
Background and Development - On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) for the Corporate Transparency Act (the “CTA”). ...more
On December 8, 2021, the U.S. Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) implementing Section 6403 of the Corporate Transparency Act (CTA), which gives the public until...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Dec. 7, 2021, seeking to implement the "beneficial ownership information" (BOI) requirement of the Corporate...more
Today’s proposed rule will greatly expand the application of reporting requirements identifying the true owners of business entities formed under U.S. law or formed under foreign laws and registered to do business in the...more
The Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA is to deter anonymous owners of corporations, limited liability companies, and other entities from...more
On April 1, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (the "Notice") seeking public comment on a myriad of issues related to the implementation of a beneficial...more