Developments concerning the enforceability and enforcement of the CTA came at a rapid clip last week. As things stand, the government may enforce the CTA pending a Texas court appeal in Smith v. U.S. Department of the...more
The Fifth Circuit has granted the government’s request to stay temporarily the order and injunction issued by the United States District Court for the Eastern District of Texas, which had issued a nationwide stay prohibiting...more
12/24/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more
8/5/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
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
On April 18, the Financial Crimes Enforcement Network (“FinCEN”) released updated FAQs related to the Corporate Transparency Act (“CTA”) and Beneficial Ownership Information (“BOI”) Rule. The last round of updates occurred in...more
The Financial Action Task Force (“FATF”) has re-rated the U.S. as “largely compliant” with FATF’s Recommendation 24, which pertains to transparency related to beneficial ownership of legal persons. Specifically, FATF...more
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)
This week, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial ownership information (“BOI”)...more
12/22/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Gramm-Leach-Blilely Act ,
Money Laundering ,
Popular ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
YouTube
The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”). They pertain, in part, to a proposed extension of the filing deadline for certain...more
10/2/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Comment Period ,
Corporate Transparency Act ,
Filing Deadlines ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
National Security ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as...more
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