News & Analysis as of

Public Comment Anti-Money Laundering Reporting Requirements

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Notice of Proposed New Beneficial Ownership Information Reporting Requirements Under the Corporate Transparency Act

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

Goodwin

FinCEN Proposes Rules Implementing Corporate Ownership Requirements Under Corporate Transparency Act to Fill Gaps in U.S....

Goodwin on

WHAT YOU NEED TO KNOW: - The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule to implement portions of the Corporate Transparency Act codified at 31 U.S.C. § 5336 (CTA). ...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Bilzin Sumberg

FinCEN Seeks Public Comment on Corporate Transparency Act

Bilzin Sumberg on

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

Goodwin

SEC Raises Concerns About Misleading ESG Practices, Highlights Potential Violations

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) Division of Examinations issued a Risk Alert raising concerns about misleading Environmental, Social, and Governance (ESG) disclosures by investment firms; the...more

King & Spalding

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

King & Spalding on

After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

Goodwin

FinCEN Proposes AML Program Requirement for Banks without a Federal Functional Regulator

Goodwin on

FinCEN has proposed extending its anti-money laundering (AML) program requirement for banks to banks that are not subject to regulation by a federal functional regulator, including state chartered limited purpose trust...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

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