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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

The Anti-Money Laundering Act Of 2020

On New Year’s Day, Congress overrode President Trump’s veto of the National Defense Authorization Act (NDAA) for the 2021 fiscal year, turning the bill into law without requiring the president’s signature. The NDAA includes...more

Financial Services Report – Winter 2020

Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...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

FinCEN Guidance: How To Hemp

On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) released guidance (the “Guidance”) on the Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations and considerations surrounding hemp-related...more

FinCEN Penalizes Individual Banker For Anti-Money Laundering Compliance Program Failures

For what appears to be only the second time, the Financial Crimes Enforcement Network (“FinCEN”) has assessed a civil money penalty (“CMP”) against an individual for Bank Secrecy Act (“BSA”) violations based on alleged...more

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