News & Analysis as of

Final Rules BSA/AML Financial Institutions

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

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On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

Jones Day

Investment Advisers Subject to AML and SARs Requirements

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The Situation: The Financial Crimes Enforcement Network ("FinCEN") has adopted a rule that subjects certain investment advisers to anti-money laundering/countering the financing of terrorism program ("AML") requirements...more

Goodwin

FinCEN Adopts Final AML Program Rule for Investment Advisers

Goodwin on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2024 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Ballard Spahr LLP

Bank and Credit Union Industry Groups Challenge Illinois Interchange Fee Prohibition Act as Unlawful and Urge the Court to Stop...

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On August 15, 2024, the Illinois Bankers Association, American Bankers Association, America’s Credit Unions, and Illinois Credit Union League filed a complaint for declaratory and injunctive relief against the Illinois...more

Ballard Spahr LLP

South Dakota Regulator Requires BSA/AML Compliance for Money Lender Licensees and Non-Residential Mortgage Lenders

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The South Dakota Division of Banking issued a Memorandum notifying all licensed money lenders and non-residential mortgage lenders of their Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) obligations under a 2020 Final...more

Cadwalader, Wickersham & Taft LLP

FinCEN Issues Beneficial Ownership Information “Access Rule”

On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule setting forth the circumstances under which beneficial ownership information reported to FinCEN pursuant to the Corporate...more

Goodwin

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

Goodwin on

On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...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

Perkins Coie

AMLA 2020 Series Part 3: FinCEN Issues Notice of Proposed AML Rules for Antiquities Dealers

Perkins Coie on

On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more

Foodman CPAs & Advisors

The BSA Casts A Wider Net

On  September 15, 2020,  FinCEN issued a Final Rule stating that Banks lacking a Federal Functional Regulator will be required to establish and implement AML programs including policies and procedures,  a dedicated compliance...more

Ballard Spahr LLP

Regulatory Round Up: FinCEN Extends BSA/AML Requirements to Banks Lacking a Federal Functional Regulator

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First Post in a Three-Post Series Regarding Recent Regulatory Action by FinCEN - The Financial Crimes Enforcement Network (“FINCEN”) has been busy. In the last two weeks, FinCEN has posted three documents in the Federal...more

Ballard Spahr LLP

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

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Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

Goodwin

Financial Services Weekly Roundup: April (Liquidity) Showers Bring May Borrower Protection

Goodwin on

In this Issue: Senate Votes to Expand Paycheck Protection Program; FHFA (Finally) Addresses Liquidity Concerns for Mortgage Servicers. Yesterday, the U.S. Senate unanimously passed legislation providing $484 billion in...more

Davis Wright Tremaine LLP

NYDFS Issues Regulation Addressing Anti-Money Laundering Transaction Monitoring and Filtering Requirements

On June 30, 2016, the New York Department of Financial Services (NYDFS) issued a final regulation obliging regulated institutions to meet enhanced requirements for transaction monitoring and filtering programs aimed at...more

King & Spalding

FinCEN Issues Final Rule on Customer Due Diligence Requirements for Legal Entity Customers

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On May 11, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) published its Final Rule (Rule) requiring covered financial institutions, including, banks, brokerdealers, mutual funds, and money...more

Kelley Drye & Warren LLP

FinCEN Publishes Final Customer Due Diligence Rules Introducing New Measures to Control Money Laundering and Other Financial...

On May 11, 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) Final Rule codifying new and existing customer due diligence (“CDD”) requirements under the Bank Secrecy Act (“BSA”) was...more

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