News & Analysis as of

New Guidance FinCEN Financial Institutions

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

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Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Ballard Spahr LLP

FinCEN Issues Alert on Countering Financing of Hizballah and Terrorist Activities

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On October 23rd, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplementary alert regarding countering financing of the U.S.-designated foreign terrorist organization Hizballah (the “Alert”). In May 2024,...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Ballard Spahr LLP

FinCEN Issues Analysis of Increasing Elder Financial Exploitation

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The Financial Crimes Enforcement Network (“FinCEN”) recently issued a Financial Trend Analysis (“Analysis”) focusing on patterns and trends identified in Bank Secrecy Act (“BSA”) data linked to Elder Financial Exploitation...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Goodwin

FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers

Goodwin on

Regulatory Developments - FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers - On January 17, FinCEN proposed a form of report to collect beneficial...more

Orrick, Herrington & Sutcliffe LLP

FinCEN offers suspicious activity reporting guidance for human smuggling along U.S.- Mexico border

On January 13, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling along the...more

Goodwin

FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards

Goodwin on

Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more

Orrick - Finance 20/20

FinCEN Urges Financial Institutions to Focus on Detecting Proceeds of Foreign Public Corruption

Orrick - Finance 20/20 on

The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

K2 Integrity on

Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

Jones Day

FinCEN Issues First U.S. Priorities for Anti-Money Laundering and Counter-Terrorism Financing

Jones Day on

On June 30, 2021, FinCEN announced the first set of government-wide AML/CFT Priorities, as required by the Anti-Money Laundering Act of 2020 ("AML Act"). Consistent with the National Strategy for Combating Terrorist and Other...more

Holland & Knight LLP

FinCEN Announces National AML/CFT Policy Priorities

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The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

ArentFox Schiff

OFAC’s New Ransomware Advisory

ArentFox Schiff on

On October 1, 2020, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an Advisory highlighting sanctions risks associated with facilitating ransomware payments on behalf of victims targeted by...more

Mitchell, Williams, Selig, Gates & Woodyard,...

The High Points: SARs and the Three Tiered Framework for MRBs

As green states continue to grow, intentional or unintentional exposure to Marijuana Related Business (“MRB”) customers for financial institutions and broker-dealers is an inevitability. Whether your business has decided to...more

White & Case LLP

Hemp Businesses and Financial Institution Due Diligence

White & Case LLP on

On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) issued guidance explaining how financial institutions can conduct due diligence for hemp-related businesses and identifying the type of information and...more

Eversheds Sutherland (US) LLP

FinCEN clarifies SAR filing and due diligence requirements for financial institutions providing services to hemp-related...

On June 29, 2020, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued guidance (the 2020 Guidance) clarifying requirements under the Bank Secrecy Act (BSA) for financial institutions providing...more

Morgan Lewis - All Things FinReg

FinCEN Provides BSA Customer Due Diligence Guidance for Hemp-Related Businesses

The Financial Crimes Enforcement Network (FinCEN) published guidance (Guidance) on customer due diligence requirements under the Bank Secrecy Act (BSA) for hemp-related customers on June 29. ...more

Goodwin

Financial Services Weekly Roundup: New Rules, Amendments And More Amid Coronavirus Outbreak

Goodwin on

In This Issue. The ongoing global outbreak of the coronavirus (COVID-19) continues to grow in scale and scope. In response, federal financial regulators are continuing efforts to bring regulatory relief to promote stability...more

Eversheds Sutherland (US) LLP

Federal agencies clarify SAR filing requirements for financial services provided to hemp-related businesses

On December 3, 2019, four federal agencies, in consultation with state banking regulators, clarified the legal status of hemp growth and production under the Bank Secrecy Act (BSA) for banks providing financial services to...more

Proskauer - Blockchain and the Law

CFTC, FinCEN, and SEC Warn of Crypto AML Enforcement

Based on a recent regulatory statement, entities involved with cryptocurrency or digital assets should revisit their anti-money laundering and countering the financing of terrorism obligations (AML/CFT) compliance under the...more

Jones Day

Financial Regulatory Leaders Highlight Anti-Money Laundering Issues With Digital Asset Transactions - Regulators highlight AML/CFT...

Jones Day on

On October 11, 2019, the heads of the U.S. Commodity Futures Trading Commission ("CFTC"), the U.S. Securities and Exchange Commission ("SEC"), and the Financial Crimes Enforcement Network ("FinCEN"), issued a joint statement...more

Allen Matkins

DBO Issues Guidance To Banks And Credit Unions Serving Cannabis Related Businesses

Allen Matkins on

In the early 1970s, I worked as a petroleum transfer engineer (aka service station attendant). In those halcyon days, we actually pumped the gas for customers, washed their windows and offered to check the oil. I remember one...more

Katten Muchin Rosenman LLP

FinCEN Publishes Guidance Pertaining to Certain Business Models Involving Convertible Virtual Currencies

On May 9, the Financial Crimes Enforcement Network of the US Department of the Treasury (FinCEN) issued guidance relating to how its regulations apply to certain businesses that transact in "convertible virtual currencies"...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Spanish

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

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