News & Analysis as of

Financial Crimes Rulemaking Process

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

Greenberg Glusker LLP

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

Epstein Becker & Green

CTA Interim Final Rule Eliminates Requirements for U.S. Companies and U.S. Individuals to File Beneficial Ownership Reports

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN), in an action that was promised earlier in March, issued an interim final rule (the “Interim Rule”) that removes all requirements for U.S. companies and...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

Fenwick & West LLP

The Corporate Transparency Act: Treasury Department Suspends Enforcement, Reporting Obligations

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In a press release issued on March 2, 2025, the Treasury Department, which oversees the Financial Crimes and Enforcement Network (FinCEN), announced that it will not enforce any penalties or fines associated with the existing...more

Morgan Lewis

FinCEN Will Not Enforce Extended Corporate Transparency Act Filing Deadlines

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Corporate Transparency Act (CTA) reporting requirements were recently reinstated, and the Financial Crimes Enforcement Network (FinCEN) established a new filing deadline of March 21, 2025. However, on February 27, 2025,...more

Troutman Pepper Locke

Investment Management Update - Q1 2024

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This update covers legal developments and regulatory news for funds, their advisers, and industry participants for the quarter ended March 31. Rulemaking and Guidance: • SEC Adopts Reforms Relating to Investment Advisers...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules in Q1 2024

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Stark & Stark

The Corporate Transparency Act and Reporting Requirements

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On January 1, 2024, the Corporate Transparency Act, 33 U.S.C. §5336, (the “CTA”) took effect and strict compliance must be met by all entities and individuals to which it applies. The CTA adds reporting requirements for...more

Seyfarth Shaw LLP

FDIC to Codify Policy under Section 19 of the Federal Deposit Insurance Act

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Seyfarth Synopsis: The Federal Deposit Insurance Corporation is accepting comments until March 16, 2020 on the proposed codification to the Statement of Policy for Section 19 of the Federal Deposit Insurance Act, as well as...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

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