News & Analysis as of

Reporting Requirements Notice of Proposed Rulemaking (NOPR) Customer Due Diligence (CDD)

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

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

Seward & Kissel LLP

FinCEN Proposes AML Requirements for Certain Investment Advisers

Seward & Kissel LLP on

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

Dechert LLP

FinCEN Corporate Transparency Notice of Proposed Rulemaking: Access to Beneficial Ownership Information and FinCEN Identifiers

Dechert LLP on

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule (Proposed Rule) on December 15, 2022, implementing the requirements of Section 6403 of the Corporate Transparency Act (Act)...more

Perkins Coie

FinCEN Issues Proposed Rule for Accessing Ownership Information Under the Corporate Transparency Act

Perkins Coie on

The U.S. Department of the Treasury’s (the Treasury) Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated final rule on September 29, 2022, implementing the beneficial ownership information (BOI)...more

King & Spalding

FinCEN Issues Final Rule for Beneficial Ownership Regulations

King & Spalding on

Implementation of Beneficial Ownership Reporting Obligations; Expanded CDD Rule Forthcoming On September 29, 2022, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule...more

Morrison & Foerster LLP

FinCEN Issues a Proposed Beneficial Ownership Rule

On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (NPRM or “Proposed Rule”) to implement the beneficial ownership information (BOI) reporting provisions of the...more

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