News & Analysis as of

Beneficial Owner Office of Foreign Assets Control (OFAC) Financial Institutions

Baker Botts L.L.P.

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

Baker Botts L.L.P. on

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

King & Spalding

Recent OFAC and DOJ Activity Signals Potential New Era of Control-Based Sanctions Enforcement

King & Spalding on

U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more

Foodman CPAs & Advisors

BOI Acceso Y Salvaguardas

El 2/20/23, FinCEN publicó la Guía de Cumplimiento para Pequeñas Entidades para los requisitos de Acceso y Salvaguardas de la información sobre los Beneficiarios Finales. La Guía de BOI Acceso y Salvaguardas (de seis páginas...more

Foodman CPAs & Advisors

BOI Access & Safeguards

On 2/20/23, FinCEN published the Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements. The (six-pages and four sections) BOI Access & Safeguards Guide provides an overview...more

Jenner & Block

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

Jenner & Block on

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

Ballard Spahr LLP

SEC Exam Priorities Target AML

Ballard Spahr LLP on

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

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

Ballard Spahr LLP on

The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Holland & Knight LLP

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

Holland & Knight LLP on

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

The Volkov Law Group

Beneficial Ownership: Sanctions and FCPA Compliance

The Volkov Law Group on

Financial institutions have been pushing back hard on FinCEN’s proposal to require banks, investment banks and other financial institutions to identify beneficial owners of account holders. As time goes on the impact of...more

The Volkov Law Group

Beneficial Ownership and AML, Sanctions and Anti-Corruption Compliance

The Volkov Law Group on

Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions, global financial institutions do not need...more

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