News & Analysis as of

Anti-Money Laundering FinCEN Comment Period

Troutman Pepper Locke

Treasury Issues Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets

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On August 18, the U.S. Department of the Treasury issued a Request for Comment, inviting interested members of the public to provide input on innovative methods to detect and mitigate illicit finance risks involving digital...more

Ballard Spahr LLP

FinCEN Issues Proposed Reporting Form for Residential Real Estate Deals

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As we previously blogged, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Final Rule,...more

Vedder Price

SEC and FinCEN Propose Customer Identification Program Requirements for Investment Advisers

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On May 13, 2024, the SEC and FinCEN jointly proposed a new rule under the Bank Secrecy Act (BSA) that would impose new customer identification program (CIP) requirements on registered investment advisers and exempt reporting...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

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On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Stinson LLP

SEC, FinCEN Propose Customer Identification Program Requirements for RIAs and ERAs

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On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking (proposed rule) that would impact how investment advisers handle...more

McGlinchey Stafford

Rescheduling Marijuana FAQs: How Do I Submit Comments on DEA’s Proposed Rules?

McGlinchey Stafford on

On May 16, 2024, the U.S. Drug Enforcement Administration (DEA) released the proposed rule (Proposed Rule) to reschedule marijuana from Schedule I to Schedule III under the Controlled Substances Act (CSA). The Office of Legal...more

Troutman Pepper Locke

FinCEN Proposes Loosening Customer Identification Program Requirements

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On March 29, the Federal Crimes Enforcement Network (FinCEN), in collaboration with other federal agencies, issued a Notice and Request for Information and Comment (Notice and Request) seeking public comment on its proposal...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

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On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

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On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Stark & Stark

Proposed AML Suspicious Activity Rule

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On February 13, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule to combat criminals and foreign adversaries from exploiting the U.S. financial system through investment...more

Troutman Pepper Locke

FinCEN Proposes Extending AML/CFT Requirements to Certain Investment Advisors

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently announced a Notice of Proposed Rulemaking (NPRM) aimed at keeping bad actors from exploiting the U.S. financial system and assets...more

Troutman Pepper Locke

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

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On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

K2 Integrity

[Webinar] Implications of FinCEN's Notice of Proposed Rulemaking on Virtual Currency Mixers - January 17th, 9:00 am PT

K2 Integrity on

Join K2 Integrity Global Co-managing Partner and Chief Strategy Officer Juan Zarate and Coinbase Global Head of Financial Crimes Compliance Valerie-Leila Jaber for a discussion of FinCEN’s notice of proposed rulemaking on...more

Ballard Spahr LLP

CTA Round-Up: FinCEN Proposes Extended CTA Filing Deadline, Revised Reporting Form, and Privacy Act Exemption; Expands CTA FAQs;...

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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

Holland & Knight LLP

FinCEN Announces Proposed Regulations for Sharing of Suspicious Activity Reports

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Jan. 24, 2022, for implementing a pilot program allowing financial institutions to share suspicious activity...more

Ballard Spahr LLP

Sharing is Caring: FinCEN Proposes Extending Sharing Suspicious Activity Reports to Foreign Affiliates

Ballard Spahr LLP on

On January 24, 2022, the Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”).  FinCEN is proposing a rule to establish a pilot program that permits certain financial institutions...more

Troutman Pepper Locke

Some Key Takeaways From the FinCEN ‎December 7, 2021 Notice of Proposed Rule Making ‎Under the ‎Corporate Transparency Act

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As a follow-up to our earlier QuickStudies ‎on the Corporate Transparency Act (“CTA”), ‎Anti-‎Money Laundering Act of 2020 ("AMLA") and art and antiquities under the AMLA, we are providing this QuickStudy to highlight a few...more

Ballard Spahr LLP

FinCEN Seeks Comments on Modernizing the AML/CFT Regime

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On December 14, the Financial Crimes Enforcement Network (“FinCEN”) issued a request for information (“RFI”), seeking comment on ways to “streamline, modernize, and update” the anti-money laundering (“AML”) and...more

Goodwin

FinCEN Proposes Rules Implementing Corporate Ownership Requirements Under Corporate Transparency Act to Fill Gaps in U.S....

Goodwin on

WHAT YOU NEED TO KNOW: - The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule to implement portions of the Corporate Transparency Act codified at 31 U.S.C. § 5336 (CTA). ...more

Herbert Smith Freehills Kramer

FinCEN Releases Proposed Rule For Beneficial Ownership Reporting Requirements To Counter Illicit Finance

The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week a Notice of Proposed Rulemaking (NPRM) to implement the beneficial ownership reporting requirements set forth in the Corporate...more

Ballard Spahr LLP

Real Estate and Money Laundering: FinCEN Issues Advanced Notice of Regulations for the Real Estate Industry

Ballard Spahr LLP on

On December 6, FinCEN announced that it was issuing an Advanced Notice of Proposed Rulemaking (“AMPRM”) to solicit public comment on potential requirements under the Bank Secrecy Act (“BSA”) for certain persons involved in...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Foodman CPAs & Advisors

FinCEN Is Seeking Feedback On The Corporate Transparency Act (CTA)

The CTA is a recent reporting requirement that is expected to enhance U.S. national security through increasing the difficulty involved for harmful actors to exploit opaque legal structures for laundering money, financing...more

Eversheds Sutherland (US) LLP

FinCEN proposes and seeks public comment on new AML Corporate Transparency Act Rulemaking

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has published an Advance Notice of Proposed Rulemaking (the Proposed Rule) seeking input from the public on the implementation of a reporting...more

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