News & Analysis as of

Anti-Money Laundering FinCEN National Credit Union Administration

King & Spalding

Fed Follows Earlier OCC, FDIC, and NCUA Orders Allowing Banks to Collect TIN Information from Third Parties

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On July 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exemptive order in coordination with the Board of Governors of the Federal Reserve System (the “Fed”) that allows...more

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on

Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Troutman Pepper Locke

Federal Agencies Issue Order Granting Exemption for Financial Institutions on TIN Collection

Troutman Pepper Locke on

The Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) (collectively, the agencies), with concurrence from the...more

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

Foodman CPAs & Advisors

FinCEN AML/CFT Regla Propuesta

El 6/29/24, FinCEN, en consulta con la Junta de Gobernadores del Sistema de la Reserva Federal, la Oficina del Contralor de la Moneda, la Corporación Federal de Seguro de Depósitos y la Administración Nacional de Cooperativas...more

Foodman CPAs & Advisors

AML/CFT FinCEN Proposed Rule

On 6/29/24, FinCEN, in consultation with the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union...more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

McGlinchey Stafford

Marijuana & Banking: What’s the Hold Up? Pt. 1 – Conflicting Legal Landscapes

McGlinchey Stafford on

Today, nearly four-fifths of the United States have regulated medical marijuana markets. Nearly half of the United States, consisting of twenty-one states along with Washington, D.C. and Guam, have acted to legalize...more

Paul Hastings LLP

Daily Financial Regulation Update -- Thursday, January 19, 2023

Paul Hastings LLP on

January 18, 2023- The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued an order that identifies the virtual currency exchange Bitzlato Limited (Bitzlato) as a "primary money laundering...more

Morgan Lewis - All Things FinReg

Agencies Emphasize Risk-Based Due Diligence Approach for Charities and Nonprofits

The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to...more

Foodman CPAs & Advisors

While FinCEN lacks Independent Litigating Authority, it is the Regulator for the BSA and is responsible for the administration of...

FinCEN issues implementing regulations that “ensure” compliance with the BSA.  FinCEN delegates its examination authority to federal agencies.  These federal agencies are the “Federal Functional Regulators” who supervise...more

White & Case LLP

Federal Banking Agencies Open a Pathway to the Provision of Banking Services to Hemp-Related Businesses

White & Case LLP on

On December 3, 2019, in a rare public statement regarding the provision of banking services to cannabis- or hemp-related businesses, the Federal Banking Agencies, including the Board of Governors of the Federal Reserve...more

Moore & Van Allen PLLC

Enhancing Transparency in the Agencies’ Approach to BSA/AML Examinations

Last month the Financial Crimes Enforcement Network (FinCEN) and the federal bank regulators issued a Joint Statement aimed at improving transparency into their risk-focused examination and supervision of banks’ compliance...more

K&L Gates LLP

Saving Grace

K&L Gates LLP on

Credit Unions Provided a Grace Period to Comply With New Customer Due Diligence Requirements - In May of 2018, the new Customer Due Diligence Requirements for Financial Institutions (the “CDD Rule”) from the Financial Crimes...more

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