News & Analysis as of

Beneficial Owner Customer Due Diligence (CDD) AML/CFT

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

BCLP

FinCEN Adopts AML/CFT Rules for Investment Advisers with Few Changes from Proposed Rules

BCLP on

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more

Ballard Spahr LLP

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

Ballard Spahr LLP on

Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...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

Perkins Coie

FinCEN’s Highly Anticipated Beneficial Ownership Reporting Rule Under CTA Effective January 1, 2024

Perkins Coie on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its highly anticipated final rule implementing the beneficial ownership information (BOI) reporting requirements of the Corporate...more

Morgan Lewis

FinCEN Releases Advance Notice of Proposed Rulemaking on New Beneficial Ownership Reporting Requirement

Morgan Lewis on

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on April 1 took the first step towards implementing the Corporate Transparency Act’s (CTA’s) beneficial ownership reporting requirements,...more

K2 Integrity

National Defense Authorization Act (NDAA) 2021: Landmark AML Reforms Pass Congress

K2 Integrity on

In the most consequential update to the Bank Secrecy Act (BSA) since the 2001 passage of the USA PATRIOT Act, the United States Congress on 11 December passed a wide-ranging bill that broadens and updates the BSA and the U.S....more

Holland & Knight LLP

Treasury Releases 2020 National Strategy for Combating Terrorist and Other Illicit Financing

Holland & Knight LLP on

The 2020 National Strategy for Combating Terrorist and Other Illicit Financing was issued earlier this month by the U.S. Department of the Treasury. Prepared in consultation with regulators and law enforcement, including the...more

Foodman CPAs & Advisors

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more

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