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Beneficial Ownership Information Reporting Rule – Update and Comparison with Beneficial Ownership Rule

Implementation of the Corporate Transparency Act (CTA)[1] is gathering momentum. Most notably, as of the new year the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) is accepting reports of...more

Federal Court Holds Financial Institution Liable for Business Email Compromise Loss

While ransomware attacks usually grab the headlines, business email compromise (BEC) attacks continue to cause massive financial losses for businesses. The FBI’s Internet Crime Complaint Center (IC3), reported BEC losses in...more

FinCEN Beneficial Ownership Information Access Proposal Raises Many Questions

As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more

FinCEN Releases Final Rule on Beneficial Ownership Information Reporting Requirements

In a purported effort to close supposed loopholes that allow illicit actors to use corporate structures such as shell companies to hide their identities and launder their ill-gotten gains in or through the United States, the...more

Addressing Digital Assets' Illicit Financing Risks: "Supporting Actions" Still Needed to Execute Treasury's Action Plan

The U.S. Treasury Department's (Treasury) September 16, 2022, release of the "Action Plan to Address Illicit Financing Risks of Digital Assets" was published in response to an Executive Order, "Ensuring Responsible...more

Corporate Transparency Act Creates National Database of Company Ownership Information

The Corporate Transparency Act (CTA), passed over President Trump's veto as part of the National Defense Authorization Act on January 1, 2021, may have a major impact on the manner in which financial institutions comply with...more

Lessons from Recent BSA/AML Enforcement Actions

On February 14, 2019, DWT FinTech co-chair Andy Lorentz gave a presentation on lessons learned from recent BSA/AML enforcement actions–a continued area of emphasis in a de-regulatory climate–to the Innovative Payment Alliance...more

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