The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of...more
10/18/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
NPRM ,
Terrorist Financing Regulations
Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more
9/13/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Reporting Requirements ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
This episode features a discussion with Nick St. John, Director of Federal Compliance at America’s Credit Unions. We discuss the Notice of Proposed Rulemaking (NPRM) issued by FinCEN and federal banking regulators regarding...more
The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...more
7/29/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Notice of Proposed Rulemaking (NOPR) ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations
FinCEN’s recent preliminary rulemaking aims to enhance and modernize regulations with requirements and priorities that affect a broad range of “financial institutions” across industries—but lacks concrete guidance on...more
7/26/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Chevron Deference ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Popular ,
Regulatory Agenda ,
Risk Assessment ,
Terrorist Financing Regulations
On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more
7/16/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Broker-Dealer ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
NPRM ,
Popular ,
Reporting Requirements ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations
After several years of monitoring and reporting on artificial intelligence (AI) in financial services, the U.S. Department of Treasury (Treasury) has embarked on initial rulemaking efforts and issued a request for information...more
6/27/2024
/ AML/CFT ,
Anti-Money Laundering ,
Artificial Intelligence ,
BSA/AML ,
Consumer Financial Products ,
Financial Institutions ,
Financial Services Industry ,
Machine Learning ,
Non-Discrimination Rules ,
Request For Information ,
Risk Management ,
U.S. Treasury ,
UDAAP
On May 13th, the Financial Crimes Enforcement Network (FinCEN) and the Securities Exchange Commission (SEC) issued a joint notice of proposed rulemaking (NPRM) that would require SEC-registered investment advisers (RIAs) and...more
5/29/2024
/ AML/CFT ,
Bank Secrecy Act ,
Customer Identification Program (CIP) ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Notice of Proposed Rulemaking (NOPR) ,
NPRM ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC)
In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more
4/12/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Consent Order ,
Customer Identification Program (CIP) ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Money Laundering ,
Risk Management ,
Terrorist Financing ,
Third-Party ,
True Lender
In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...more
4/10/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Consent Order ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Regulation E ,
Risk Assessment ,
Terrorist Financing Regulations ,
True Lender
On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more
2/23/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Corporate Transparency Act ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
NPRM ,
Real Estate Investments ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
Without much fanfare, the Financial Crimes Enforcement Network (FinCEN) published in June its Spring 2023 Rulemaking Agenda, which provides proposed timelines for upcoming key rulemakings projected throughout the rest of...more
7/10/2023
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Final Rules ,
FinCEN ,
Money Laundering ,
NPRM ,
Regulatory Agenda ,
Rulemaking Process ,
Suspicious Activity Reports (SARs) ,
Whistleblower Awards