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On June 27, the OCC, FDIC and NCUA, with the concurrence of FinCEN, granted an exemption allowing banks to use a third party source to obtain customer tax identification numbers (TIN) for customers before opening an account....more
Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more
The U.S. Drug Enforcement Agency’s proposal to reschedule cannabis from a Schedule I to a Schedule III drug under the Controlled Substances Act (CSA) has generated considerable buzz across business sectors, including for the...more
Today, nearly four-fifths of the United States have regulated medical marijuana markets. Nearly half of the United States, consisting of twenty-one states along with Washington, D.C. and Guam, have acted to legalize...more
On September 29, 2022, the Financial Crimes Enforcement Network (FinCEN) issued the first of three final rules implementing the Corporate Transparency Act’s beneficial ownership information (BOI) requirements. The aim of the...more
Most entities formed or registered to do business in the U.S. will, beginning January 1, 2024, be required to self-report beneficial ownership information to the U.S. Treasury’s Financial Crimes Enforcement Network...more
In its most recent Marijuana Banking Update, the Financial Crimes Enforcement Network (FinCEN) stated that the decline in the number of banks and credit unions actively banking marijuana-related businesses (MRBs) in the...more
The Financial Crimes Enforcement Network (“FinCen”) issued a Marijuana Related Business update in June with data from the first quarter of 2017. FinCen reports that the number of depository institutions that are actively...more