News & Analysis as of

U.S. Treasury Anti-Money Laundering NPRM

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

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on

On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Lowenstein Sandler LLP

U.S. Treasury Issues Notice of Anti-Money Laundering Regulations for Residential Real Estate Transfers

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On Feb. 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM)1 in response to illicit finance risks identified in the U.S. residential real estate...more

Lowenstein Sandler LLP

U.S. Treasury Renews Push to Make Investment Advisers Subject to the BSA

Lowenstein Sandler LLP on

The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more

BakerHostetler

Treasury Revisits Past Rulemaking to Bring Investment Advisers Under AML Oversight

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In connection with the Biden Administration’s ongoing crackdown on corruption, tax havens, and illicit financing, on December 11, Treasury released a Fact Sheet on its “efforts to address the illicit finance and national...more

Latham & Watkins LLP

FinCEN Seeks Enhanced Oversight of Crypto Mixing

Latham & Watkins LLP on

A proposed rule would increase Treasury’s insight into non-US crypto mixing transactions to combat illicit activities by malicious actors. On October 19, 2023, the US Department of the Treasury’s Financial Crimes...more

Nutter McClennen & Fish LLP

The Corporate Transparency Act: FinCEN to Collect Beneficial Ownership Information

The Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA is to deter anonymous owners of corporations, limited liability companies, and other entities from...more

Dechert LLP

FinCEN Proposes Anti-Money Laundering Regulation for Investment Advisers

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015,1 pertaining to all investment advisers registered or required to be registered...more

Skadden, Arps, Slate, Meagher & Flom LLP

"A Long Time Coming: FinCEN Proposes AML Program and SAR Requirements for Investment Advisers"

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would impose certain anti-money laundering (“AML”) requirements on...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Proposes New Rule Requiring Anti-Money Laundering Programs for Registered Investment Advisers

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that would define investment advisers registered (or required to be registered) with the Securities and...more

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