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The Financial Action Task Force (“FATF”) has re-rated the U.S. as “largely compliant” with FATF’s Recommendation 24, which pertains to transparency related to beneficial ownership of legal persons. Specifically, FATF...more
The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as...more
The US Treasury’s Financial Crimes Enforcement Network (FinCEN) recently proposed a new rule (the Proposed Rule) regarding beneficial ownership information access and safeguards pursuant to the Corporate Transparency Act....more
Starting this year (2022), most private, domestic U.S. entities formed from and after January 1, 2021 will be required to self-report to the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) certain basic...more
In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more
The Anti-Money Laundering Act of 2020 was a game-changing piece of legislation. Perhaps the most important provision is the expansion of beneficial ownership regulatory authority....more
On December 7, 2021, the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting...more
The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has published an Advance Notice of Proposed Rulemaking (the Proposed Rule) seeking input from the public on the implementation of a reporting...more