According to the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) states that the main focus for Financial Institution ought to be on the reporting of suspicious activities....more
7/23/2018
/ Banking Sector ,
Financial Fraud ,
Financial Institutions ,
FinCEN ,
Fraudulent Transfers ,
Money Laundering ,
Reporting Requirements ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
Third-Party Risk ,
Third-Party Service Provider
Los inversionistas de la Moneda Virtual (MV) utilizan los servicios de plataformas en línea "seguros" para comprar, vender, transferir y almacenar la MV. Los proveedores de estos servicios se conocen como “wallets,...more
The Suspicious Activity Report (SAR) was originally created by five federal financial supervisory agencies (Federal Reserve Board, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Office of...more
Virtual Currency (VC) investors are currently investing without clarity regarding which Government Agency(s) has the final word with respect to the treatment of VC. US Agencies: IRS, FinCEN, SEC and CFTC – have expressed...more
5/11/2018
/ Bitcoin ,
CFTC ,
Commodities ,
Cryptocurrency ,
Digital Currency ,
FinCEN ,
IRS ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Oversight ,
Securities ,
Securities and Exchange Commission (SEC) ,
Tax Planning ,
Trading Platforms ,
Virtual Currency
Investors in Virtual Currency (VC) utilize the services of on-line “secure” platforms for buying, selling, transferring, and storing VC. The providers of these services are known as web-wallets (Coinbase is an example). ...more
Covered Financial Institutions (CFI) have until May 11, 2018 to implement and comply with the Financial Crimes Enforcement Network (FinCEN) Final Customer Due Diligence Rule (the CDD Rule). The CDD Rule imposes a new...more
There is a new Bill drafted on November 14, 2017 called the Counter Terrorism and Illicit Finance Act (CTIFA). The Bill is currently in a committee in the Senate and it proposes a substantial overhaul to the Bank Secrecy Act...more
US Taxpayers (which includes US Citizens, Permanent Residents, Trusts, Estates, and Domestic Entities) with an interest in foreign financial accounts that meet the reporting threshold of an aggregate value exceeding $10,000...more
There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more
1/15/2018
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Filing Requirements ,
Financial Institutions ,
FinCEN ,
Foreign Ownership ,
IRS ,
Reporting Requirements ,
Required Forms ,
Tax Planning ,
U.S. Treasury
On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018. The CDD Rule applies to Covered Financial Institutions (federally...more
On 8/25/17, President Donald Trump signed an Executive Order (EO) restricting and prohibiting certain transactions between US Persons and Venezuela. The transactions that are prohibited by US Persons apply wherever a US...more
10/23/2017
/ Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
FinCEN ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
SDN List ,
Trump Administration ,
Venezuela
On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New...more
10/16/2017
/ Bank Secrecy Act ,
Beneficial Owner ,
Cash Transactions ,
Covered Transactions ,
FinCEN ,
Geographic Targeting Order ,
GTO ,
Limited Liability Company (LLC) ,
Money Laundering ,
Popular ,
Real Estate Investments ,
Real Estate Transactions ,
Shell Corporations ,
Tax Evasion ,
Wire Transfers
Under the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) issued a “Fifth Pillar” of the Final Customer Due Diligence (CDD) Rule on May 2016. The covered financial institutions (Banks; Brokers or...more
Recently FinCEN issued Advisory (FIN-2016-A003) regarding e-mail compromise schemes that defraud Financial Institutions by deceiving them into conducting wire transfers that result in misappropriated customers funds. The...more
Bank Secrecy Act of 1970
- Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more
10/14/2016
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Cross-Border Transactions ,
Currency Transaction Reports (CTR) ,
Disclosure Requirements ,
FATF ,
FBAR ,
Financial Institutions ,
FinCEN ,
Internal Revenue Code (IRC) ,
IRS ,
Money Laundering ,
Patriot Act ,
Reporting Requirements ,
Required Forms ,
Risk Management ,
Sanctions ,
Shell Corporations ,
Surveillance ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
Terrorist Threats ,
Wiretapping
Because they are known as “gatekeepers” in the financial industry, Professional Service Providers (PSPs), Bankers, Brokers, Realtors, Casino Managers, Trust Fund Managers, Money Managers, etc., carry a level of responsibility...more
8/8/2016
/ Accountants ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Customer Due Diligence (CDD) ,
Due Diligence ,
FATF ,
Financial Institutions ,
FinCEN ,
Real Estate Agents ,
Recordkeeping Requirements ,
Suspicious Activity Reports (SARs)
After the Panama Papers, and with the recent FinCEN final Customer Due Diligence (CDD) rule, U.S. financial institutions are further focused on tightening internal controls against money laundering, terrorist financing,...more