On June 28, 2024, The U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (the “Proposed Rule”) that would amend FinCEN’s anti-money laundering (“AML”) program rules for...more
On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more
2/26/2024
/ Anti-Money Laundering ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Proposed Rules ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule setting forth the circumstances under which beneficial ownership information reported to FinCEN pursuant to the Corporate...more
2/9/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Ownership Interest ,
Regulatory Requirements ,
Reporting Requirements
Two recent OFAC enforcement actions highlight real-world challenges that financial institutions and other companies may face in their efforts to implement an effective sanctions compliance program....more
On January 1, 2021, Congress enacted the Anti-Money Laundering Act of 2020 (the “Act”). As part of the National Defense Authorization Act for Fiscal Year 2021, the Act creates a broad range of new anti-money laundering...more