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FinCEN Final Rule for Beneficial Ownership Reporting: The “Substantial Control” Prong

Second Post in a Two-Post Series on the CTA Implementing Regulations - As we just blogged, the Financial Crimes Enforcement Network (“FinCEN”) has issued a final rule (“Final Rule”) regarding the beneficial ownership...more

Closing the Gate—House Adopts ENABLERS Act Amendment to 2023 NDAA

Amendment Focuses on Professional “Gatekeepers” – Lawyers, Accountants, Payment Processors, and Those Providing Corporate Formation and Trust Services - On July 13, 2022, the House of Representatives (the “House”) adopted...more

More from FinCEN to Financial Institutions on the Kleptocracy – With a Continued Focus on Russia

On April 14, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory on kleptocracy and foreign public corruption. At a high level, the advisory stresses the importance of financial institutions focusing...more

Circular Delegation: Amicus Support By Former FinCEN Officials and the Cato Institute in the Alpine Securities Saga

Amicus Briefs Urge that Only FinCEN, Not the SEC, Should Enforce the BSA in Regards to Broker-Dealers - In the next stage of the Alpine Securities saga (as we blogged about here, here and here), a petition for a writ of...more

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