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FinCEN’s Final Regulations to Implement the Corporate Transparency Act

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

FinCEN Issues Final Regulations to Implement the BSA’s Revised Beneficial Ownership Requirements

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

FinCEN Urges Financial Institutions to Guard Against Attempts to Evade Sanctions

On March 7, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “FinCEN Alert”) urging financial institutions to proactively guard against possible attempts to evade recently implemented sanctions...more

FinCEN Proposes Regulations to Implement the BSA’s Revised Legal Entity Requirements

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on December 8, 2021, the Financial Crimes Enforcement...more

Current Bank Capital and Enforcement Action Considerations

Because of the devastating effect that the COVID-19 pandemic has had on the entire U.S. economy, the federal Bank Regulators have warned of the possibility that small, medium and large banks may soon be forced to recognize...more

National Financial Institutions - Developing A Project Plan To Comply With The California Consumer Privacy Act

Since its adoption last year, U.S. financial institutions have been confronted with the challenge of planning their compliance with the California Consumer Privacy Act (the “CCPA”). The CCPA becomes effective in two stages -...more

Clarification From FinCEN — Updating Marijuana Limited SARs

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the Treasury, issued guidance on February 14, 2014 (the “Cannabis Guidance”), to clarify Bank Secrecy Act expectations for financial...more

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