News & Analysis as of

Paycheck Protection Program (PPP) FinCEN CARES Act

McGlinchey Stafford

FinCEN Update to Beneficial Ownership FAQs and Paycheck Protection Program FAQs

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In January 2024, the Financial Crimes Enforcement Network (FinCEN) updated and added to its Frequently Asked Questions (FAQs) on the Beneficial Ownership Information Report (BOI) website. Additionally, on January 12, 2024,...more

Steptoe & Johnson PLLC

Federal Authorities Focusing on PPP Fraud

Steptoe & Johnson PLLC on

With the light at the end of the tunnel getting brighter on our pandemic journey, the legal realities are only just beginning. The Department of Justice has prioritized the prosecution of fraud arising from the Paycheck...more

Skadden, Arps, Slate, Meagher & Flom LLP

Closer Scrutiny Expected of Corporate Conduct

The Biden administration is widely expected to be tougher on corporate wrongdoing than its predecessor. Although there have not yet been significant changes to existing policies, key nominations to date and early enforcement...more

Ballard Spahr LLP

New PPP Procedural Requirements Reflect Lenders’ Emerging AML Duties

Ballard Spahr LLP on

The Small Business Administration (“SBA”) recently issued a procedural notice (the “Notice”) to “All SBA Employees and Paycheck Protection Program Lenders” setting forth “Revised SBA Paycheck Protection Platform Procedures...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2021

HUD, VA, and USDA Coordinate Extensions of COVID-19 Relief for Homeowners - The U.S. Department of Housing and Urban Development (HUD), the U.S. Department of Veterans Affairs (VA), and the U.S. Department of Agriculture...more

Ballard Spahr LLP

FinCEN Issues PPP Lender Guidance

Ballard Spahr LLP on

With the third round of lending through the Paycheck Protection Program (“PPP”) in full swing, the Small Business Administration (“SBA”) – administrator of the PPP – has developed new guidance in consultation with the United...more

Ballard Spahr LLP

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

Ballard Spahr LLP on

Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2020

SBA Issues Instructions to Lenders on Submitting PPP Loan Forgiveness Applications The U.S. Small Business Administration (the “SBA”) has issued a procedural notice announcing that the SBA will begin accepting forgiveness...more

Ballard Spahr LLP

FATF Issues Paper on COVID-19 Enhanced AML and Fraud Risks

Ballard Spahr LLP on

On May 4, the Financial Action Task Force (“FATF”) issued a paper entitled “Covid-19-Related Money Laundering and Terrorist Financing – Risk and Policy Responses (“Paper”). ...more

Foodman CPAs & Advisors

FinCEN re-clarifies FAQ’s on how Lenders can meet BSA requirements when issuing PPP loans

On April 13, 2020, FinCEN, as the administrator of the BSA, re-published FAQs on how borrowers and lenders may rely on the guidance provided for the SBA’s interpretation of the CARES Act and of the PPP (Paycheck Protection...more

Manatt, Phelps & Phillips, LLP

Bank Secrecy Act Compliance Issues for Small-Business Lending Under the CARES Act

With many banks and credit unions electing to limit Paycheck Protection Program (PPP) loans to existing customers, many nonbank lenders are scrambling to fill the gap and take part in the $349 billion program prior to the end...more

Davis Wright Tremaine LLP

AI Meets the Paycheck Protection Program: FinCEN FAQs Underscore How the Regulatory Response to the Pandemic Is Accelerating the...

The COVID-19 pandemic provides a stark reminder about the importance of responding to rapid changes in a timely and expeditious manner. In the span of a few weeks, unemployment levels have skyrocketed to unprecedented levels,...more

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