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Reporting Requirements AML/CFT

Conyers

Regulatory & Risk Advisory Review: Cayman Islands – July to September 2024

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Welcome to the third Regulatory & Risk Advisory Review instalment of 2024. In this edition we cover the latest Cayman Islands regulatory updates including the Beneficial Ownership Transparency Act and The Perpetuities...more

Kohn, Kohn & Colapinto LLP

FinCEN Issues Final Rule: Implications for Real Estate Money Laundering

The Financial Crimes Enforcement Network (FinCEN), a bureau within the United States Department of Treasury, has issued a new investment advisor rule to protect residential real estate from illicit finance, such as money...more

Walkers

Cayman Islands beneficial ownership regime: Update and progress towards 1 January 2025

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How does the beneficial ownership reporting regime developments impact those within the fund governance function? Introduction - As noted in our recent advisory, the Cayman Islands' beneficial ownership reporting...more

Cozen O'Connor

Corporate Transparency Act Compliance

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The federal Corporate Transparency Act (CTA) requires disclosure of information about all corporations, limited liability companies and limited partnerships (unless exempt), and personal information about their beneficial...more

Hahn Loeser & Parks LLP

90 Days and Counting for the Initial CTA Deadline

Time is running out. We are now in the 4th quarter of 2024 and despite legal challenges and proposed actions in the legislature, the year-end Corporate Transparency Act (“CTA”) reporting deadline remains incumbent upon...more

Walkers

Channel Islands Regulatory Update: October 2024

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The financial services sector in the Channel Islands has seen the publication of a report by MONEYVAL, a proposal to increase administrative penalties and the release of two public statements. The Bailiwick gambling...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

A&O Shearman

UK Office of Financial Sanctions Implementation Annual Frozen Asset Review

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The Office of Financial Sanctions Implementation has published a financial sanctions notice reminding firms of their annual frozen assets reporting requirement. Every year HM Treasury carries out a review to update its...more

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

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On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

Eversheds Sutherland (US) LLP

FinCEN adopts investment adviser AML rules

The Financial Crimes Enforcement Network (FinCEN) adopted a final rule that adds most federal Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to the definition of “financial institution” under the...more

Ballard Spahr LLP

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

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The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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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

White & Case LLP

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

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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

K2 Integrity

[Webinar] AML/CFT Rules for Investment Advisers - June 12th, 9:30 am PT

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On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

Foodman CPAs & Advisors

Directora Gacki De FinCEN Fomenta La Transparencia En El Sistema Financiero De EE. UU

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

Akin Gump Strauss Hauer & Feld LLP

AIFMD II Comes into Force in April 2024

The final text of the amendments to the EU Alternative Investment Fund Managers Directive (AIFMD)—known as “AIFMD II”—was published in the Official Journal of the European Union on March 26, 2024, and will enter into force on...more

American Conference Institute (ACI)

[Event] 23rd Annual Canadian Forum on Anti-Money Laundering and Financial Crime - June 5th - 6th, Toronto, Ontario, Canada

Hosted by the Canadian Institute, the 23rd Annual Canadian Forum on Anti-Money Laundering and Financial Crime returns for another exciting year. The event features carefully curated programming providing practical guidance...more

Perkins Coie

Federal District Court Finds Corporate Transparency Act Unconstitutional: What Now?

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The CTA and Legal Challenges - The CTA is a sweeping new anti-money-laundering law that, as of January 1, 2024, requires most entities formed or registered to do business in the United States to disclose detailed...more

WilmerHale

FinCEN Re-Proposes AML/CFT Requirements Covering Investment Advisers

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On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more

Dechert LLP

Treasury Proposes Investment Advisers AML/CFT Program Rule

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Treasury proposed a new rule that would require investment advisers to establish an AML/CFT program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Proposed Rule). The Proposed Rule...more

Seward & Kissel LLP

FinCEN Proposes AML Requirements for Certain Investment Advisers

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On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more

Foster Swift Collins & Smith

The Corporate Transparency Act's Impact on ESOPs

The Corporate Transparency Act (“CTA”), which became effective on January 1, 2024, requires that many businesses report a significant amount of information about the company and its “beneficial owners” to a federal database....more

Morrison & Foerster LLP

FinCEN Proposes Expanding Residential Real Estate Anti-Money Laundering Rules

On February 16, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking, which would require certain real estate professionals to report certain transaction information to FinCEN in...more

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

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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

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