News & Analysis as of September 8, 2025

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

Fed Follows Earlier OCC, FDIC, and NCUA Orders Allowing Banks to Collect TIN Information from Third Parties

King & Spalding on 8/11/2025

On July 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exemptive order in coordination with the Board of Governors of the Federal Reserve System (the “Fed”) that allows...more

FinCEN's October 2024 Beneficial Ownership Information FAQ Update

Seyfarth Shaw LLP on 10/11/2024

On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

CTA Compliance Obligations for CTA Participants: Reporting Companies, Beneficial Owners, and Third-Party Preparers

Dorsey & Whitney LLP on 5/10/2024

In an evolving (and somewhat disjointed) process, FinCEN has been providing guidance to persons and entities that are responsible for filing required beneficial ownership information (“BOI”) reports to FinCEN, as well as to...more

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

King & Spalding on 2/27/2024

The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

El Identificador FinCEN

Foodman CPAs & Advisors on 12/5/2023

El 29 de septiembre del 2023, FinCEN actualizó las preguntas frecuentes (“FAQs”) sobre los Reportes de Información sobre los Beneficiarios Reales (“BOI”), incluyendo orientación sobre el Identificador FinCEN. Las preguntas...more

The FinCEN Identifier

Foodman CPAs & Advisors on 12/5/2023

On September 29, 2023, FinCEN updated the FAQs regarding Beneficial Ownership Information (BOI) Reporting, including guidance on the FinCEN identifier. The FinCEN’s BOI FAQs work in tandem with the FinCEN’s BOI Small...more

Financial Services Report – Winter 2020

Morrison & Foerster LLP on 12/11/2020

Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more

When Bank Account Activity is not Consistent with the Customer’s Business

Foodman CPAs & Advisors on 7/23/2018

According to the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) states that the main focus for Financial Institution ought to be on the reporting of suspicious activities....more

Banks to Broaden Reporting of Suspicious Cyber Activity; Regulators Propose “Enhanced” Cybersecurity Standards

Carlton Fields on 11/23/2016

The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more

New Interagency Guidance Clarifies CIP Requirements for Prepaid Cards

Bryan Cave Leighton Paisner on 3/26/2016

On March 21, 2016, FinCEN and the federal bank regulatory agencies published Guidance to issuing banks on the CIP requirements applicable to prepaid cards. While the Guidance referred to “prepaid cards,” footnote 5 to the...more

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FinCEN › Third-Party Service Provider

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