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Financial Institutions › Data Collection › FinCEN

Alston & Bird

Financial Institutions Permitted to Use Third Parties to Collect Customers’ Taxpayer Identification Numbers for Identity...

Alston & Bird on

Our Financial Services and White Collar, Government & Internal Investigations Teams examine the Financial Crimes Enforcement Network’s new customer identification program (CIP) exemption that allows banks and credit unions to...more

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Bradley Arant Boult Cummings LLP on

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

McGlinchey Stafford

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on

In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

Morrison & Foerster LLP on

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Foodman CPAs & Advisors

Is the “FinCEN Query” a Gateway to Convergence?

Foodman CPAs & Advisors on

FinCEN’s (a bureau of the U.S. Department of the Treasury) primary purpose is  protecting the financial system from illicit use, combating money laundering, and promoting national security through the collection, analysis,...more

Foley Hoag LLP - White Collar Law &...

U.S. Senate Considering Update to Federal Anti-Money Laundering System

Foley Hoag LLP - White Collar Law &... on

A bipartisan group of Senators, with the support of the American Bankers Association, recently introduced bill S.2563, known as the ILLICIT Cash Act. The acronym “ILLICIT” stands for “Improving Laundering Laws and Increasing...more

Vedder Price

Annual Compliance Obligation Reminders

Vedder Price on

Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more

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