News & Analysis as of

Reporting Requirements Bank Secrecy Act Beneficial Owner

Foodman CPAs & Advisors

Residential Real Estate and FinCEN

FinCEN seeks to safeguard residential real estate as evidenced by the issuance of the Final Residential Real Estate Rule issued 8/28/24 and taking effect on 12/1/25. The Final Rule requires “certain” industry professionals...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Locke Lord LLP

FINCEN Adopts New Rule on Cash Sales ‎of Residential Real Estate

Locke Lord LLP on

On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) published a final rule (the “Rule”) requiring reports by “reporting persons” concerning real estate transfers to a legal entity or trust of certain...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Finalizes Rule to Compel Reporting of Individuals and Beneficial Ownership of Entities Involved in Specified Transfers of...

FINCEN’s final rule (RRE Rule), effective December 1, 2025, will require disclosure of the transferor and transferee(s) and the individuals and the beneficial owners of entities involved as transferee in the transfer of...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

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The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

Foodman CPAs & Advisors

Acceso A BOI: Enfoque Gradual De FinCEN

El 4/18/24, FinCEN actualizó su sección de preguntas frecuentes y agregó una nueva sección titulada “Acceso a información de BOI”. Esta nueva sección aborda el enfoque gradual de FinCEN para brindar acceso a BOI (información...more

Foodman CPAs & Advisors

Access To BOI: FinCEN Phased Approach

On 4/18/24, FinCEN updated its FAQ Section and added a new section titled “Access to BOI Information”. This new section addresses the phased approach from FinCEN to providing access to BOI – beneficial ownership information –...more

Dechert LLP

Treasury Proposes Investment Advisers AML/CFT Program Rule

Dechert LLP on

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

Foodman CPAs & Advisors

Reporte Real Estate De FinCEN

El 7 de febrero de 2024, FinCEN emitió un Aviso de Reglamentación Propuesta (NPRM) para combatir y disuadir el lavado de dinero en el sector inmobiliario residencial de EE. UU. mediante el aumento de la transparencia. FinCEN...more

Foodman CPAs & Advisors

Real Estate Report From FinCEN

On February 07, 2024, FinCEN issued a Notice of Proposed Rulemaking (NPRM) to combat and deter money laundering in the U.S. residential real estate sector by increasing transparency. FinCEN is seeking to require certain...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

McGlinchey Stafford

FinCEN Issues Access Rule, Small Entity Compliance Guide for Beneficial Ownership Information

McGlinchey Stafford on

The Corporate Transparency Act (CTA) requires certain businesses to provide beneficial ownership information (BOI) to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). BOI received by FinCEN...more

Holland & Knight LLP

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

Holland & Knight LLP on

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

Ballard Spahr LLP

FinCEN Proposes BSA Reporting Requirements for Residential Real Estate

Ballard Spahr LLP on

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

Troutman Pepper

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

Troutman Pepper on

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

Amundsen Davis LLC

Enhancing Transparency in Real Estate: FinCEN's New Reporting Requirements for Non-Financed Transfers

Amundsen Davis LLC on

On February 7, 2024Real Estate Contract FinCEN issued a Notice of Proposed Rulemaking that would require certain professionals involved in real estate closings and settlements to report information to FinCEN about...more

Foodman CPAs & Advisors

BOI Destinatarios Autorizados

El 12/21/23, FinCEN emitió una regla final que implementa las disposiciones de acceso y salvaguardia de la Ley de Transparencia Corporativa (CTA) (la “Regla de Acceso”). La Regla de Acceso tiene como objetivo garantizar que:...more

Foodman CPAs & Advisors

BOI Authorized Recipients

On 12/21/23, FinCEN issued a final rule implementing the access and safeguard provisions of the Corporate Transparency Act (CTA) (the “Access Rule”). The Access Rule aims to ensure that: (1) only BOI authorized recipients...more

Husch Blackwell LLP

Corporate Transparency Act Guide

Husch Blackwell LLP on

On January 1, 2024, the Corporate Transparency Act (CTA) will go into effect, and if your business is deemed to be a Reporting Company under the CTA, the clock will begin ticking on new federal reporting obligations....more

Ballard Spahr LLP

A Roadmap to the CTA’s Game-Changing Reporting Requirements

Ballard Spahr LLP on

Beginning on January 1, 2024, many U.S. legal entities and foreign entities registered to do business in the U.S. will be required to report information about themselves, their beneficial owners, and their company applicants...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

Ballard Spahr LLP on

The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

K2 Integrity

SEC Division of Examination Risk Alert Highlights Deficiencies in Broker-Dealers’ AML Compliance Programs

K2 Integrity on

The U.S. Securities and Exchange Commission (SEC) is responsible for protecting investors and ensuring the integrity of the securities markets. As part of this mission, the SEC requires broker-dealers to comply with...more

Dorsey & Whitney LLP

FinCEN Issues Final Regulations to Implement the BSA’s Revised Beneficial Ownership Requirements

Dorsey & Whitney LLP on

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

Cozen O'Connor

FinCEN Issues Final Regulation for Beneficial Ownership Reporting

Cozen O'Connor on

On September 30, 2022, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued the first of three regulations to implement Section 6403 of the Corporate Transparency Act. FinCEN...more

Fuerst Ittleman David & Joseph

FinCEN Issues Final Rule for Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) promulgated its much-anticipated Final Rule implementing the beneficial ownership reporting scheme mandated by the Corporate Transparency Act....more

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