How Will the Anti-Money Laundering Act of 2020 and the Corporate Transparency Act Impact Banks’ Anti-Money Laundering Compliance Under the Bank Secrecy Act? A Discussion with Guest Matt Haslinger
Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)
In an era of increasingly sophisticated financial crimes and evolving regulatory, compliance, and internal audit needs, financial institutions must continuously refine their risk assessment strategies. Traditional methods,...more
Conducting an independent AML audit at a frequency based on the nature, scale and complexity of the entity is a requirement under the AML Regulations. AML audits are an important component of the control environment to...more
China’s draft Amended Anti-Money Laundering (AML) Law1 (AML Law) was submitted to the Standing Committee of the National People's Congress (NPC) on September 10 for the second of what are generally three readings....more
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more
Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more
On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more
A press release was recently issued describing a significant joint proposal by the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The proposal...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more
The Corporate Transparency Act (CTA) was enacted in 2021 and became effective on Jan. 1, 2024. The CTA was passed with the aim of enhancing transparency in corporate ownership, so as to combat the proliferation of anonymous...more
Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more
The Corporate Transparency Act (CTA), which was passed by Congress in 2021 and is administered by the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury, will become effective on January 1,...more
Last month, the U.S. Securities and Exchange Commission (SEC) took a refreshed look at how broker-dealers are complying with anti-money laundering rules. What auditors discerned — as detailed in their July 31 risk alert — is...more
On July 31, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMS) issued a risk alert summarizing observations from its recent anti-money laundering (AML) and counter-financing of terrorism...more
On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more
As NFTs gain popularity, buyers and sellers should consider the potential issues related to federal anti-money laundering laws. While non-fungible tokens (“NFTs”) have existed for several years, the market for NFTs grew...more
The Canadian Institute’s 20th Canadian Annual Forum on AML and Financial Crime is a curated program, dedicated to addressing pressing industry challenges through in-depth analysis of the financial crime landscape and industry...more
Blog after blog, commentator after commentator, and everyone else who has an opinion has been repeating the same message – the Biden Administration is going to increase enforcement risks....more
Individuals, trusts and companies buying or selling art via UK galleries and auction houses will now be subject to the same customer due diligence checks as those opening bank accounts in the UK. What has changed? The...more
Compliance professionals, we need to talk about suspicious activity reporting. The regulators say we’re not doing it well enough. ...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly...more
Financial institutions face a pending deadline to meet new customer due diligence requirements. FinCEN has issued updated Frequently Asked Questions to assist financial institutions in understanding the scope of the...more
Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more
Chief compliance officers for financial institutions are going to have a rough May 2018. First, on May 11, 2018, the new CDD Rule for beneficial ownership becomes effective. Two weeks later, on May 25, 2018, the EU’s...more