News & Analysis as of

Suspicious Activity Reports (SARs) FinCEN Public Comment

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

Goodwin

FinCEN Proposes Rule for SARs Sharing Pilot Program

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more

Holland & Knight LLP

FinCEN Seeks Public Input to Reduce Vulnerability of Real Estate Market to Money Laundering

Holland & Knight LLP on

The Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (Notice) on Dec. 9, 2021, requesting public comment on ways to enhance the transparency of the domestic real estate market...more

Goodwin

Federal Agencies Issue Joint Statement on Management of LIBOR Transition

Goodwin on

In This Issue. Federal agencies issued a joint statement regarding an orderly transition away from the London Interbank Offered Rate (LIBOR); the Office of the Comptroller of the Currency (OCC) issued an updated...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

White & Case LLP

FinCEN Invites Comments on Anti-Money Laundering Program Effectiveness

White & Case LLP on

On September 16, the US Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) seeking to update the US anti-money laundering (AML) regime. This is an historic opportunity for...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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