News & Analysis as of

Anti-Money Laundering Customer Due Diligence (CDD) Financial Institutions

Hogan Lovells

DAM(L’d) if you do, DAM(L’d) if you don’t – What should regulated firms be thinking about now the PoCA consent threshold has been...

Hogan Lovells on

On 10 July 2025, the UK raised the threshold below which certain regulated firms can perform acts that would otherwise constitute a money laundering offence. The new threshold is £3,000. This is the second rise in the...more

K2 Integrity

AI-Driven Risk Assessment: Enhancing Financial Crime Compliance And Internal Audit

K2 Integrity on

In an era of increasingly sophisticated financial crimes and evolving regulatory, compliance, and internal audit needs, financial institutions must continuously refine their risk assessment strategies. Traditional methods,...more

Ankura

Quality Control Unveiled: Insights from Transaction Monitoring

Ankura on

Ensuring high-quality standards in any organization is an essential ingredient that must be rooted within a company’s Quality Management Program (QMP) – a program that creates a framework to ensure quality....more

Ankura

Identity Theft and How To Prevent It

Ankura on

Imagine sitting in your living room, enjoying a cup of your favorite morning coffee, and you open your mail to discover that you recently opened a new bank account at XYZ Bank, unbeknownst to you. Or maybe you receive an...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on

Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

K2 Integrity

Pending FinCEN Investment Adviser Rule: Industry Perspective On Next Steps You Should Be Taking

K2 Integrity on

On 22 August 2024, K2 Integrity hosted a webinar discussing considerations related to the pending anti-money laundering rule (AML) for investment advisers (IAs) from the Financial Crimes Enforcement Network (FinCEN). The...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

Latham & Watkins LLP on

On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

Ballard Spahr LLP on

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

Troutman Pepper Locke

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

Troutman Pepper Locke on

Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Ballard Spahr LLP

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

Ballard Spahr LLP on

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

Troutman Pepper Locke

FinCEN Proposes Rule to Strengthen AML/CFT Programs

Troutman Pepper Locke on

On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Ballard Spahr LLP

FinCEN Releases Updated BOI FAQs

Ballard Spahr LLP on

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

Ballard Spahr LLP

Recent FDIC consent orders show increased regulation scrutiny of bank relationships with fintech partners

Ballard Spahr LLP on

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

Ballard Spahr LLP

FATF Re-Rates United States as “Largely Compliant” with Beneficial Ownership Recommendation

Ballard Spahr LLP on

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

Troutman Pepper Locke

FUNDamentals: FinCEN [Re]Proposes Anti-Money Laundering Rules for Investment Advisers

Troutman Pepper Locke on

On February 13, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule that would require federal investment advisers to add Bank Secrecy Act (“BSA”) type anti-money...more

Ballard Spahr LLP

Federal District Court Ruling: The CTA is Unconstitutional

Ballard Spahr LLP on

On March 1, Judge Liles C. Burke of the Northern District of Alabama issued a Memorandum Opinion (“Opinion”) and Final Judgment, finding that the Corporate Transparency Act (“CTA”) is unconstitutional....more

Troutman Pepper Locke

FinCEN Proposes New Investment Adviser AML Rule

Troutman Pepper Locke on

On February 1/3, the Financial Crimes Enforcement Network (FinCEN) proposed a new rule (the Proposed Rule), that, if adopted, would add certain investment advisers to the definition of “financial institution” under the Bank...more

Cadwalader, Wickersham & Taft LLP

FinCEN Proposes New Rule Requiring AML Compliance Programs for Investment Advisers

On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more

McGuireWoods LLP

FinCEN Issues Access Rule Compliance Guide for Beneficial Ownership Information

McGuireWoods LLP on

Rule Regarding Access to Beneficial Ownership Information Takes Effect - On February 21, 2024, FinCEN published a Small Entity Compliance Guide to aid in compliance with the Corporate Transparency Act’s (“CTA”) Beneficial...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

Mayer Brown

Third Time’s the Charm? Anti-Money Laundering Compliance Requirements Proposed for Registered and Exempt Reporting Investment...

Mayer Brown on

On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more

Holland & Knight LLP

FinCEN Issues Final Rule Implementing Access and Safeguard Provisions of the CTA

Holland & Knight LLP on

The Corporate Transparency Act (CTA) was enacted in 2021 and became effective on Jan. 1, 2024. The CTA was passed with the aim of enhancing transparency in corporate ownership, so as to combat the proliferation of anonymous...more

Dorsey & Whitney LLP

FinCEN’s Final Regulations to Implement the Corporate Transparency Act

Dorsey & Whitney LLP on

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

Troutman Pepper Locke

Federal Agencies Issue Access Rule to Beneficial Ownership Information Pursuant to the CTA

Troutman Pepper Locke on

On December 21, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Financial Crimes Enforcement Network (FinCen), the National Credit Union Administration, along with...more

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