Popular, Anti-Money Laundering, Customer Due Diligence (CDD)

PEP talk revisited: revised UK guidance on treatment of PEPs

A&O Shearman on 8/14/2025

The UK Financial Conduct Authority (FCA) has issued finalised guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes. There is no significant shift in the FCA’s expectations of...more

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on 10/24/2024

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

China Amends Its Anti-Money Laundering Law

WilmerHale on 10/1/2024

China’s draft Amended Anti-Money Laundering (AML) Law1 (AML Law) was submitted to the Standing Committee of the National People's Congress (NPC) on September 10 for the second of what are generally three readings....more

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on 9/19/2024

Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

FinCEN Releases Updated BOI FAQs

Ballard Spahr LLP on 4/30/2024

On April 18, the Financial Crimes Enforcement Network (“FinCEN”) released updated FAQs related to the Corporate Transparency Act (“CTA”) and Beneficial Ownership Information (“BOI”) Rule. The last round of updates occurred in...more

FUNDamentals: FinCEN [Re]Proposes Anti-Money Laundering Rules for Investment Advisers

Troutman Pepper Locke on 3/8/2024

On February 13, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule that would require federal investment advisers to add Bank Secrecy Act (“BSA”) type anti-money...more

Federal District Court Ruling: The CTA is Unconstitutional

Ballard Spahr LLP on 3/4/2024

On March 1, Judge Liles C. Burke of the Northern District of Alabama issued a Memorandum Opinion (“Opinion”) and Final Judgment, finding that the Corporate Transparency Act (“CTA”) is unconstitutional....more

Third Time’s the Charm? Anti-Money Laundering Compliance Requirements Proposed for Registered and Exempt Reporting Investment...

Mayer Brown on 2/16/2024

On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more

The Corporate Transparency Act: Ready, Set, Go!

Bilzin Sumberg on 1/2/2024

It’s official: the Corporate Transparency Act (the “Act”) has gone into effect January 1, 2024. On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) issued its second final rule establishing the framework...more

Federal Agencies Issue Access Rule to Beneficial Ownership Information Pursuant to the CTA

Troutman Pepper Locke on 12/27/2023

On December 21, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Financial Crimes Enforcement Network (FinCen), the National Credit Union Administration, along with...more

FinCEN Issues Final CTA BOI Access Rules, Heralded by YouTube Video

Ballard Spahr LLP on 12/22/2023

This week, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial ownership information (“BOI”)...more

FinCEN Expands CTA FAQs

Ballard Spahr LLP on 11/17/2023

On November 16, the Financial Crimes Enforcement Network (“FinCEN”) issued – again –expanded FAQs pertaining to beneficial ownership information (“BOI”) reportable under the Corporate Transparency Act (“CTA”). These expanded...more

A Roadmap to the CTA’s Game-Changing Reporting Requirements

Ballard Spahr LLP on 10/26/2023

Beginning on January 1, 2024, many U.S. legal entities and foreign entities registered to do business in the U.S. will be required to report information about themselves, their beneficial owners, and their company applicants...more

The FCA’s 2023/24 Priorities for UK Payments: Firms and Investors, Take Note

Goodwin on 3/21/2023

On March 16, 2003, the UK Financial Conduct Authority (FCA) published its letter Portfolio Letter: FCA priorities for payments firms to the CEOs of UK Payment Institutions (PIs), Electronic Money Institutions (EMIs), and...more

Financial Crimes Enforcement Network Makes Ransomware a Priority

Troutman Pepper Locke on 2/15/2022

On January 13, Him Das, the acting head of the Financial Crimes Enforcement Network (FinCEN), highlighted ransomware as a chief national security risk. At the Financial Crimes Enforcement Conference, Das suggested that the...more

The Anti-Money Laundering Act and Crypto Collide: Non-Fungible Tokens

King & Spalding on 5/19/2021

As NFTs gain popularity, buyers and sellers should consider the potential issues related to federal anti-money laundering laws. While non-fungible tokens (“NFTs”) have existed for several years, the market for NFTs grew...more

New BSA/AML Regime Promises Sweeping Changes

King & Spalding on 12/23/2020

As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more

National Defense Authorization Act (NDAA) 2021: Landmark AML Reforms Pass Congress

K2 Integrity on 12/22/2020

In the most consequential update to the Bank Secrecy Act (BSA) since the 2001 passage of the USA PATRIOT Act, the United States Congress on 11 December passed a wide-ranging bill that broadens and updates the BSA and the U.S....more

Developments in Cryptocurrency in 2018

Akin Gump Strauss Hauer & Feld LLP on 9/24/2018

• The U.S. Securities and Exchange Commission (SEC) staff made official statements regarding when a token may or may no longer be a security • The SEC continued to bring actions related to cryptocurrency offerings against...more

A closer look: EU-wide - Tighter AML controls imposed by Europe’s Fifth Anti-Money Laundering Directive

A&O Shearman on 8/7/2018

The EU continues to tighten its grip on money laundering. Hot on the heels of the Fourth Anti-Money Laundering Directive (4MLD), which Member States had to implement by June last year, we now have the next instalment – the...more

SEC, FINRA Target ICOs, Cybersecurity, Secondary Market Trading in 2018 Examination Priorities

Herbert Smith Freehills Kramer on 3/2/2018

Both the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) recently released their respective 2018 examination priorities, providing a glimpse into their plans for the year to...more

2016 Year in Review: Money Laundering (Part One)

Ballard Spahr LLP on 2/3/2017

2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

A System of Voluntary Self-Identification in the World of Virtual Currencies

Troutman Pepper Locke on 10/7/2016

On 5th July 2016, the European Commission (the “Commission”) published a proposal for a Directive amending the Fourth Money Laundering Directive (“Proposed Directive”), which sets out, amongst other things, to bring into...more

FinCEN Expands Crackdown on Real Estate Buyers

The Volkov Law Group on 8/24/2016

Building on early successes, the Financial Crimes Enforcement Network (“FinCEN”) announced new rules targeting buyers of high-end real estate properties. Earlier this year, FinCEN adopted rules focusing on high-end...more

European Banking Authority Opines on Virtual Currencies and the Fourth Anti-Money Laundering Directive

A&O Shearman on 8/23/2016

The European Banking Authority published an Opinion on the Commission’s proposed amendments to the Fourth Anti-Money Laundering Directive and its application to virtual currencies. The Commission is proposing to bring...more

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