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FinCEN Weighs Path to a No-Action Letter Process

On Friday, FinCEN published an Advance Notice of Proposed Rulemaking (ANPRM) as it further considers implementing a no-action letter process related to anti-money laundering compliance. The ANPRM follows a 2021 FinCEN...more

FinCEN Issues a Proposed Beneficial Ownership Rule

On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (NPRM or “Proposed Rule”) to implement the beneficial ownership information (BOI) reporting provisions of the...more

FinCEN Looks to Regulate the Real Estate Market

On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more

AMLA Implementation: FinCEN Requests Input On Beneficial Ownership Rule

Following the enactment of the Anti-Money Laundering Act of 2020 (AMLA), which encompasses the Corporate Transparency Act (CTA), the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed...more

FinCEN Requests Industry Input For Improving AML Program Effectiveness

On September 17, 2020, the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed Rulemaking (ANPR) in the Federal Register, seeking comments on how to improve the effectiveness of anti-money...more

Financial Services Report, Summer 2020

Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more

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