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Beneficial Owner Recordkeeping Requirements

Winthrop & Weinstine, P.A.

Client Alert: Corporate Transparency Act (CTA) Reporting Requirements Update

The Financial Crimes Enforcement Network (FinCEN) has reinstated the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA).  Following recent court decisions, the deadline...more

Orrick, Herrington & Sutcliffe LLP

FDIC receives letter from senators to finalize its custodial accounts rule

On January 16, the FDIC received a letter from Sens. Ron Wyden (D-OR) and John Fetterman (D-PA) urging the finalization of a proposed rule to strengthen recordkeeping for custodial accounts. As previously covered by...more

Davis Wright Tremaine LLP

FDIC Proposes Rulemaking on Custodial Deposit Accounts in Wake of Synapse Bankruptcy

As part of a larger effort to address risks related to third-party deposit relationships, on October 2, 2024, the Federal Deposit Insurance Corporation (FDIC) announced and published a notice of proposed rulemaking (Proposed...more

Alston & Bird

FDIC Proposes Rule to Establish Custodial Account Recordkeeping Requirements

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Our Financial Services Team studies the Federal Deposit Insurance Corporation’s plans to require insured depository institutions (IDIs) to keep specific records so that they know the actual owner of deposits placed by...more

Bradley Arant Boult Cummings LLP

New FDIC Recordkeeping Requirements: Director Chopra Cautions Against a New Form of “Rent-a-Bank”

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) rulemaking board proposed new recordkeeping rules intended to bolster the FDIC’s ability to make deposit insurance determinations for accounts that are...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

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The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

King & Spalding

FinCEN’s Final Rule on Anti-Money Laundering for Residential Real Estate Transfers

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On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule under the Bank Secrecy Act (“BSA”) requiring certain persons involved in real estate closings and settlements to report and maintain...more

Seward & Kissel LLP

Q&A on FinCEN’s New AML Requirements for Certain Investment Advisers

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more

WilmerHale

Corporate Transparency Act: First Wave of Required Reports Due Starting on March 31, 2024

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As we have previously reported, the Corporate Transparency Act (“CTA”) is a broad anti-money laundering law intended to assist law enforcement in combating illicit financial activity. The CTA’s beneficial ownership reporting...more

Dorsey & Whitney LLP

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

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Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

Ballard Spahr LLP

FinCEN Proposes BSA Reporting Requirements for Residential Real Estate

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On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more

Perkins Coie

Corporate Transparency Act Will Require Disclosure of Senior Officers and Directors of Many US and Foreign Companies

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The Corporate Transparency Act (CTA) became law on January 1, 2021, and requires companies formed and/or operating in the United States to disclose beneficial ownership information through a database that will be maintained...more

Perkins Coie

The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024

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Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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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

Walkers

What can we learn from recent enforcement actions in the Cayman Islands?

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Walkers' regulatory partners Lucy Frew and Ian Mason consider the learning points for financial services providers (FSPs) from recent enforcement actions by Cayman regulatory bodies. While financial services and related...more

Brooks Pierce

[Webinar] AI Usage in the Workplace and the Employment Implications of the Corporate Transparency Act (CTA) - July 20th, 10:00 am...

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Brooks Pierce attorneys Beth Langley, Kemper Patton and Mark Davidson will present a labor and employment webinar on July 20 titled, “AI Usage in the Workplace and the Employment Implications of the Corporate Transparency...more

Stoel Rives LLP

In Case You Missed It - Interesting Items for Corporate Counsel - November 2022

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The SEC adopted final clawback rules last month, here, a mere seven years after they were originally proposed! After publication of the final rules in the federal register (soon), stock exchanges must propose listing...more

White & Case LLP

Changes in ultimate beneficial owners recording legislation – a modified definition of the ultimate owner and broader reporting...

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On 1 October 2022, an amendment to Act No. 37/2021 Coll., on keeping record of ultimate beneficial owners (the "UBO Act"), 1 came into force which, in order to ensure compliance with the pertinent European Directive,2...more

Goodwin

FinCEN Finalizes Rule Implementing beneficial Ownership Reporting Requirements Under the CTA

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Regulatory Developments - FinCEN Finalizes Rule Implementing Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act - On September 29, FinCEN issued a final rule under the CTA requiring each...more

Conyers

Recent Amendments to BVI Company Law: Four Key Changes

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There have recently been a number of amendments to BVI company law. While many of these amendments are technical and will not have a material impact on clients, there are four key changes of which clients should be aware. All...more

Herbert Smith Freehills Kramer

FinCEN Considers New Anti-Money Laundering Reporting Requirements For All-Cash Real Estate Transactions

The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a proposed rule that would address the...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

International Lawyers Network

Establishing A Business Entity In Cyprus (Updated)

1. INTRODUCTION - Having been a former British colony for several years of its history (from 1878 until its independence in 1960), the legal system of the Republic of Cyprus (hereinafter “Cyprus”) follows, to a great...more

Latham & Watkins LLP

Key Regulatory Developments in Hong Kong and Singapore: December 2020

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Regulators consult on an investor identification regime and outsourcing requirements, and issue guidance on electronic storage of regulatory records and environmental risk management - This blog post summarises key...more

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