News & Analysis as of

Banks Bank Secrecy Act FinCEN

Orrick, Herrington & Sutcliffe LLP

FDIC Approves Use of Pre-Populated Customer Information During Account Opening

On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more

Orrick, Herrington & Sutcliffe LLP

Fed joins agencies in allowing banks to access tax ID numbers from third parties

On July 31, the Fed, with the concurrence of FinCEN, issued an order exempting banks supervised by the Fed from a Customer Identification Program (CIP) rule implementing Section 326 of the USA PATRIOT Act. As previously...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Lowenstein Sandler LLP

Three Banks Targeted by FinCEN in FEND Off Fentanyl Act Actions: What to Know

Lowenstein Sandler LLP on

On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more

Bradley Arant Boult Cummings LLP

$3B TD Bank AML Settlement Is A Wake-Up Call For All Banks

On Oct. 10, Attorney General Merrick Garland announced that TD Bank pled guilty to conspiracy to commit money laundering and agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice's...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

Lowenstein Sandler LLP on

On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Ballard Spahr LLP

Corporate Transparency Act Litigation Update:  Eleventh Circuit Hears Argument, and District of Oregon Rejects Preliminary...

Ballard Spahr LLP on

Various industry groups have filed lawsuits in multiple federal districts challenging the constitutionality of the Corporate Transparency Act (“CTA”). The first such suit, filed in the Northern District of Alabama, resulted...more

McGlinchey Stafford

What Would Cannabis Rescheduling Mean for Lending and Payments Legality?

McGlinchey Stafford on

The U.S. Drug Enforcement Agency’s proposal to reschedule cannabis from a Schedule I to a Schedule III drug under the Controlled Substances Act (CSA) has generated considerable buzz across business sectors, including for the...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

Perkins Coie on

The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...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 Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

Ballard Spahr LLP on

On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - February 2024 # 4

Troutman Pepper Locke on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Husch Blackwell LLP

Cannabis Banking: What’s a Financial Institution to Do Right Now?

Husch Blackwell LLP on

When I started representing cannabis businesses in 2010, the biggest epidemic in the industry next to I.R.C. 280E was the overwhelming lack of cannabis banking. This inability to access financial institutions for just...more

Ballard Spahr LLP

Bipartisan Group of Senators Re-Introduce the Digital Asset Money Laundering Act

Ballard Spahr LLP on

Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs - On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more

Troutman Pepper Locke

Bank Secrecy Act's Crypto Expansion Is on the Horizon

Troutman Pepper Locke on

The Dec. 14, 2022, introduction of the Digital Asset Anti-Money Laundering Act by Sens. Elizabeth Warren, D-Mass., and Roger Marshall, R-Kan., marks the end of a tumultuous year in the cryptocurrency industry that saw a...more

Foodman CPAs & Advisors

CDD Friendly Reminder From The Agencies To The Banks

On 7/6/22, the Agencies (Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the...more

McGuireWoods LLP

FinCEN Issues Statement on BSA Due Diligence for Independent ATM Owners and Operators

McGuireWoods LLP on

On June 22, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a Statement on Bank Secrecy Act Due Diligence for independent ATM owners and operators. The purpose of the statement is to “provide clarity to banks...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $200 Million in Penalties for BSA-AML Violations

On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $9 Million in Penalties for BSA-AML Violations

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) and the Financial Crimes Enforcement Network (“FinCEN”) issued civil monetary penalties against a Texas community bank for violations of the Bank...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

McGlinchey Stafford

BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]

McGlinchey Stafford on

The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more

The Volkov Law Group

The Transformative Role of “National AML Priorities” for Compliance in the AML Act of 2020

The Volkov Law Group on

It would be the height of folly to claim that a single theme dominates the AML Act of 2020 (Act). The new law, enacted on January 1 of this year, is an extraordinarily wide-ranging and long overdue reform of the Bank Secrecy...more

Foodman CPAs & Advisors

Agencies Request Information To Assist With BSA Laws And Regulations Compliance

On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more

62 Results
 / 
View per page
Page: of 3

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide