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Financial Crimes Regulatory Requirements Reporting Requirements

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

Ropes & Gray LLP

FinCEN Delays AML Program Rule for Investment Advisers

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On July 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it intends to delay implementation of its final rule, Anti-Money Laundering/Countering the Financing of Terrorism...more

A&O Shearman

FATF report identifies vulnerabilities in counter proliferation financing

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The Financial Action Task Force (FATF) has published a report and accompanying press release, highlighting significant vulnerabilities in the global financial system's ability to combat proliferation financing (PF) and...more

Holland & Knight LLP

CFPB Provides Guidance on Referrals for Potential Criminal Enforcement

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The CFPB has issued a policy statement describing its plan to address criminally liable regulatory offenses. President Donald Trump previously issued an executive order on May 9, 2025, requiring each federal agency to publish...more

McDermott Will & Emery

Anzeigen digital – BaFin ermöglicht zukünftig digitale Anzeigen zu Geldwäschebeauftragten

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Die Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) öffnet ihr Portal der Melde- und Veröffentlichungsplattform (MVP-Portal) zukünftig auch für geldwäscherechtliche Anzeigen. Konkret betrifft dies alle im Voraus...more

Orrick, Herrington & Sutcliffe LLP

Senators pen bipartisan letter arguing rescission of Treasury rule

On May 27, Sens. Sheldon Whitehouse (D-RI) and Charles Grassley (R-IA) wrote to the Treasury encouraging recission of the interim final rule requiring “foreign reporting companies,” but not domestic entities or U.S. citizens,...more

Conyers

Country Update - Bermuda: AML

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Bermuda is a leading international financial centre and maintains a comprehensive body of primary legislation relating to money laundering and terrorist financing, supported by a range of general and sector specific guidance...more

Morrison & Foerster LLP

CFTC Advisory Outlines Materiality Criteria for Enforcement Referrals

On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more

Mayer Brown

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

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On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

Hogan Lovells

Changes in Beneficial Ownership rules under the new EU Anti-Money Laundering Regulation (EU) 2024/1624

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The adoption of the EU Anti Money Laundering Regulation (EU) 2024/1624 (the “AML Regulation") marks a significant advancement in the European Union's efforts to combat money laundering and terrorist financing. Effective from...more

A&O Shearman

UK Financial Intelligence Unit SARS report published

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The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...more

Downs Rachlin Martin PLLC

Corporate Transparency Act – FinCEN Announces Domestic Reporting Companies Exempt From Filing

As promised, in order to reduce the burdens on placed on legitimate businesses, while still working to detect, prevent, and prosecute financial crimes, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN)...more

Goulston & Storrs PC

Corporate Transparency Act 2.0 – Narrowing Reporting Requirements

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On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that significantly changes the reporting requirements under the Corporate Transparency Act (“CTA”).  This alert summarizes...more

Ropes & Gray LLP

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

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On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

Stikeman Elliott LLP

Alert: Changes to Canadian AML Regime Affecting Cheque Cashing, Factoring and Financing and Leasing Businesses in Effect April 1,...

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Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations are being amended to introduce anti-money laundering and anti-terrorist financing obligations for factoring, financing and leasing, and cheque...more

K&L Gates LLP

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

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On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more

Kohrman Jackson & Krantz LLP

The Treasury Department Introduces a New Twist in the CTA Saga

On March 2, 2025, the U.S. Department of Treasury threw a new twist into the ongoing Corporate Transparency Act (CTA) enforcement saga by announcing that it will not enforce any fines or penalties against any U.S. citizens or...more

A&O Shearman

FSB letter to G20 finance ministers and central bank governors ahead of meeting

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The Financial Action Task Force (FATF) has published a second consultation on payment transparency, and in particular proposed revisions to recommendation 16 (R.16). The revisions adapt the FATF Standards to the changes in...more

Proskauer - Regulatory & Compliance

Ping-Pong Match Appears Over: US Companies Apparently Definitively Relieved of Compliance Obligations Under the Corporate...

The Corporate Transparency Act (the CTA) requires a range of entities, primarily smaller, unregulated companies, to file reports with FinCen, and arm of the Treasury Department, identifying the entities’ beneficial owners,...more

White and Williams LLP

Latest Corporate Transparency Act Update from FinCEN: Enforcement Paused, For Now

Stay tuned – another shoe is likely to drop from Washington D.C. on the CTA (“Corporate Transparency Act”) in the next three weeks. As we previously reported on February 18, 2025, the U.S. District Court for the Eastern...more

Shumaker, Loop & Kendrick, LLP

Client Alert: The Treasury Department Announces It Will Not Issue Fines or Penalties in Connection with Beneficial Ownership...

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced it will “…not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Beneficial Ownership Information (BOI) Reporting Requirements are Back

On February 17, 2025, the U.S. District Court for the Eastern District of Texas, in Smith et al. v. U.S. Department of the Treasury et al., stayed (lifted) the injunction blocking the enforcement of the Corporate Transparency...more

Shipkevich PLLC

BOI Reporting Back in Effect: Compliance Required by March 21, 2025

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On February 19, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that most reporting companies under the Corporate Transparency Act (CTA) must now submit their Beneficial Ownership Information (BOI) reports...more

UB Greensfelder LLP

What the Latest Reinstatement of the Corporate Transparency Act Means

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Filing requirements under the Corporate Transparency Act (CTA) have been reinstated. Per FinCEN’s (Financial Crimes Enforcement Network’s) most recent Alert released on February 18, 2025, the new deadline for filing...more

Ballard Spahr LLP

CTA Reporting Requirements Reinstated With March 21 Deadline for Most Reporting Companies

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As a result of a decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Department of the Treasury on Tuesday, February 18, beneficial ownership information (BOI) reporting requirements under...more

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