News & Analysis as of

Beneficial Owner BSA/AML Regulatory Requirements

Carlton Fields

FinCEN Postpones Opening Night for RIA AML Programs

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On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone, for two years, the effective date of a final rule subjecting investment advisers to the anti-money laundering (AML)...more

Constangy, Brooks, Smith & Prophete, LLP

Wire Fraud: Should banks CYA by tightening up on KYC?

After a long weekend, Finance Manager Joe sits at his desk to read his emails. One of the emails is from a trusted vendor with whom the Joe communicates on a regular basis, regarding an unpaid invoice that is due immediately....more

Conyers

BVI Corporate Review – Q2 2025

Conyers on

As outlined in our Q1 2025 review, important amendments to BVI company law came into effect as of 2 January 2025, including a requirement to file beneficial ownership information through the VIRRGIN system maintained by the...more

Cadwalader, Wickersham & Taft LLP

FinCEN's Proposed Streamlined SAR -- The Real Estate Report

On February 16, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule addressing “Anti-Money Laundering Regulations for Residential Real Estate Transfers.” The proposed rule would, among other...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on

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

Cadwalader, Wickersham & Taft LLP

FinCEN Issues Beneficial Ownership Information “Access Rule”

On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule setting forth the circumstances under which beneficial ownership information reported to FinCEN pursuant to the Corporate...more

Bilzin Sumberg

FinCEN Seeks Public Comment on Corporate Transparency Act

Bilzin Sumberg on

On April 1, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (the "Notice") seeking public comment on a myriad of issues related to the implementation of a beneficial...more

Lippes Mathias LLP

The Corporate Transparency Act: New Beneficial Ownership Reporting Requirements for Companies

Lippes Mathias LLP on

Earlier this year, Congress voted to override former President Trump’s veto of the 2021 National Defense Authorization Act (“NDAA”). The Corporate Transparency Act (“CTA”), enacted as part of the NDAA, requires “reporting...more

Foodman CPAs & Advisors

How will the AML Act of 2020 (the “Act”) Required Examiner Training Impact your Financial Institution?

Section 6307 of the Act requires annual Anti-Money Laundering and Countering the Financing of Terrorism training for Examiners.  The training is to be done in consultation with FinCEN and all levels of law enforcement,...more

Foodman CPAs & Advisors

La Ley Contra el Lavado de Dinero del 2020 Puede Cambiar las Reglas del Juego para los Profesionales del Cumplimiento

El 2 de diciembre del 2020, la Cámara de Representantes de los EE. UU. aprobó la “Ley de Autorización de Defensa Nacional William M. (Mac) Thornberry para el año fiscal 2021“. La Ley incluye la DIVISIÓN F (ANTI-LAVADO DE...more

Burr & Forman

A “Clean” Start to 2021: Changes to Federal Anti-Money Laundering Laws

Burr & Forman on

In a surprise bout of bipartisanship, and overriding a presidential veto, both chambers of Congress signaled a new priority for 2021—the strengthening of federal anti-money laundering provisions, albeit by an unexpected...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Ballard Spahr LLP

Shell Company Update: Congress and FATF Target Beneficial Ownership

Ballard Spahr LLP on

U.S. House Passes Corporate Transparency Act; FATF Issues Guidance on Identifying Entities’ Beneficial Owners - First Post in a Two-Post Series on Beneficial Ownership - As we often blog, the issue of the beneficial...more

Ballard Spahr LLP

Lawmakers Renew Effort to Overhaul AML Laws, Including Greater Beneficial Ownership Transparency

Ballard Spahr LLP on

The Issue of Who Truly Runs and Owns Entities Contines to Gnaw at Congress and Law Enforcement - First Post in a Two-Post Series on the ILLICIT CASH Act - On June 10, a bipartisan group of lawmakers in the U.S. Senate...more

Foodman CPAs & Advisors

LAW ENFORCEMENT and OTHERS DISSAPOINTED with ULTIMATE BENEFICIAL OWNERSHIP DRAFT LEGISLATION

There is a Bill (H.R. 6068), originally drafted on November 14, 2017, called the Counter Terrorism and Illicit Finance Act (CTIFA). The Bill intended to propose a substantial overhaul to the Bank Secrecy Act (BSA). ...more

Sullivan & Worcester

FFIEC Examination Procedures for the Beneficial Ownership Rule

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The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more

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