News & Analysis as of

BSA/AML Financial Crimes Financial Regulatory Reform

Troutman Pepper Locke

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

DLA Piper

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

DLA Piper on

Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

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The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

Troutman Pepper Locke

FinCEN Proposes Rule to Strengthen AML/CFT Programs

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On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Cadwalader, Wickersham & Taft LLP

FinCEN Proposes New Rule Requiring AML Compliance Programs for Investment Advisers

On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more

Falcon Rappaport & Berkman LLP

FinCEN’s Anti-Money Laundering Regulations for Residential Real Estate Transfers

To crack down on money-laundering in the U.S. residential real estate market, the Financial Crimes Enforcement Network (“FinCEN”) has proposed new reporting requirements for certain real estate transactions. Specifically, the...more

Ballard Spahr LLP

FinCEN Issues Final CTA BOI Access Rules, Heralded by YouTube Video

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This week, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial ownership information (“BOI”)...more

Ballard Spahr LLP

Bipartisan group of Senators re-introduce Digital Asset Money Laundering Act

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On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing...more

Foodman CPAs & Advisors

¿Cómo Afectará a su Institución Financiera la Capacitación de Examinadores requerida bajo la Ley ALD del 2020 (El Acto)?

La sección 6307 del Acto (“AML ACT of 2020”) requiere la capacitación anual para Examinadores sobre la lucha contra el lavado de dinero y el financiamiento del terrorismo. La capacitación debe realizarse en consulta con...more

K2 Integrity

New U.S. Law’s Impacts on Non-U.S. Financial Institutions

K2 Integrity on

The U.S. Anti-Money Laundering Act of 2020 (AML Act) became law on January 1 when the United States Congress passed the broader National Defense Authorization Act for 2021 over a presidential veto. Although it is a U.S. law,...more

Hogan Lovells

Financial institutions general regulatory news, December 2020 # 3

Hogan Lovells on

Sanctions and Anti-Money Laundering Act 2018 (Commencement No 2) Regulations 2020 - The Sanctions and Anti-Money Laundering Act 2018 (Commencement No 2) Regulations 2020 (SI 2020/1535) were made on 14 December 2020. ...more

Morgan Lewis

Congress Creates Enhanced Whistleblower Program for AML Violations

Morgan Lewis on

As part of a modernization of the nation’s anti-money laundering regime, the Anti-Money Laundering Act of 2020 creates enhanced whistleblower rewards that are likely to lead to increased enforcement action....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

Ballard Spahr LLP

Corporate Transparency Act of 2019 Broadens Beneficial Ownership Reporting

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In early March, the House Financial Services Committee released three proposed bills to codify many of the suggested reforms discussed during ongoing conversation among financial agencies, law enforcement, financial...more

Ballard Spahr LLP

The House Financial Services Committee Releases Proposed Legislation to Codify BSA/AML Reform Initiatives

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Last week, the House Financial Services Committee released three proposed bills to codify many of the reform ideas that have arisen in an ongoing conversation among financial agencies, law enforcement, financial institutions,...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

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