News & Analysis as of

Beneficial Owner Due Diligence Financial Institutions

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more

Holland & Hart LLP

The Corporate Transparency Act Compliance Deadline Looms—Lenders, Are Your Customers Ready? Are YOU Ready?

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The January 1, 2025, deadline imposed by the Corporate Transparency Act (CTA) for all “reporting companies” formed prior to 2024 to file their initial beneficial ownership reports with FinCEN is rapidly approaching. Given the...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Proskauer Rose LLP

Wealth Management Update - December 2023

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Shining a Light on the Corporate Transparency Act: FinCEN’s Rules for Beneficial Ownership Reporting - On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering...more

Ballard Spahr LLP

SEC Exam Priorities Target AML

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Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update – FinCEN Issues Notice of Proposed Rulemaking

On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “NPRM”) that would implement provisions of the Corporate Transparency Act (the “CTA”) regarding access to...more

Ballard Spahr LLP

Using Art to Evade Sanctions and Launder Money: The Senate Report

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Is Art an “Ideal Playing Ground” for Money Laundering? Last week, the Permanent Subcommittee on Investigations for the U.S. Senate released a detailed, 147-page report titled “The Art Industry and U.S. Policies That...more

Ballard Spahr LLP

FinCEN Issues Exceptive Relief from Beneficial Ownership Rule to Certain Account Renewals

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FinCEN Cites Low Risk of Money Laundering and High Regulatory Burden of Rule - On September 7, 2018, the Financial Crimes Enforcement Network (“FinCEN”) issued permanent exceptive relief (“Relief”) to the Beneficial...more

Ballard Spahr LLP

FinCEN Issues Latest Advisory on FATF-Identified Jurisdictions with AML/CFT Deficiencies

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On September 15th, FinCEN issued its latest “Advisory on FATF-Identified Jurisdictions with AML/CTF Deficiencies.” The FATF, or the Financial Action Task Force, is a 37-member intergovernmental body, including the United...more

The Volkov Law Group

Beneficial Ownership Due Diligence Requirements

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The new FinCEN regulations requiring financial institutions to secure beneficial ownership information is fast approaching – May 2018. The US has been way behind in this regulatory area. As a result, money-laundering activity...more

Goodwin

FinCEN Issues Final Customer Due Diligence Rule

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The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has expanded the due diligence obligations of certain financial institutions that are subject to a customer identification program requirement under...more

A&O Shearman

US Treasury Announces Measures to Enhance Anti-Money Laundering, Bank Secrecy Act Compliance and Tax Evasion Rule Compliance

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The US Treasury Department put forth several measures to combat money laundering, corruption and tax evasion, in the wake of the so-called “Panama Papers” document leak. First, the US Treasury issued a final Customer Due...more

Cadwalader, Wickersham & Taft LLP

FinCEN Issues Final Rules for Customer Due Diligence Requirements

On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued the final version of its long-awaited “Customer Due Diligence Rules” under the Bank Secrecy Act. The final rules impose a new requirement on...more

Carlton Fields

FinCEN Unveils “Fifth Pillar” of Anti-Money Laundering Compliance

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The idea that a “fifth pillar” of Anti-Money Laundering (“AML”) compliance – customer due diligence requiring U.S. banks, broker-dealers, mutual funds, commodity futures merchants, and introducing brokers (“covered financial...more

Ballard Spahr LLP

FinCEN Finalizes Beneficial Ownership Identification Rules

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As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more

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