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Proposed Rules Anti-Money Laundering AML/CFT

Vedder Price

FinCEN Postpones Effective Date of Investment Adviser Anti-Money Laundering Requirements

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone by two years the effective date of the final rule that it adopted on August 28, 2024...more

BCLP

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

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FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

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

King & Spalding

What Does a Second Trump Administration Mean for the Private Funds Industry?

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The incoming Trump administration will bring significant changes to regulatory policy as it relates to the asset management industry, and private funds, in particular...more

BCLP

FinCEN Adopts AML/CFT Rules for Investment Advisers with Few Changes from Proposed Rules

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more

Goodwin

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

Goodwin on

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

King & Spalding

FinCEN’s Final Rule on Anti-Money Laundering for Residential Real Estate Transfers

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On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule under the Bank Secrecy Act (“BSA”) requiring certain persons involved in real estate closings and settlements to report and maintain...more

Troutman Pepper Locke

FinCEN Proposes AML/CFT ‎Augmentation Rule

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On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) intended to strengthen and modernize U.S. financial institutions’...more

K2 Integrity

[Webinar] Pending FinCEN Investment Advisor Rule: Industry Perspective on Next Steps You Should Be Taking - August 22nd, 12:30 pm...

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Join our panel of experts for a 60-minute session to discuss the pending Financial Crimes Enforcement Network (FinCEN) Investment Advisory Rule and what steps industry should be taking to prepare. The panel will include Sarah...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Troutman Pepper Locke

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

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As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

Foodman CPAs & Advisors

FinCEN AML/CFT Regla Propuesta

El 6/29/24, FinCEN, en consulta con la Junta de Gobernadores del Sistema de la Reserva Federal, la Oficina del Contralor de la Moneda, la Corporación Federal de Seguro de Depósitos y la Administración Nacional de Cooperativas...more

Foodman CPAs & Advisors

AML/CFT FinCEN Proposed Rule

On 6/29/24, FinCEN, in consultation with the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Proposes Rule To Strengthen US Anti-Money Laundering and Countering the Financing of Terrorism Programs

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule (the Proposed Rule) to implement certain aspects of the Anti-Money Laundering Act of 2020 (the AML Act), which updated the...more

Holland & Knight LLP

FinCEN Issues Proposed Rule Amending Requirements of Financial Institutions' AML/CFT Programs

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more

Troutman Pepper Locke

FinCEN Proposes Rule to Strengthen AML/CFT Programs

Troutman Pepper Locke on

On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Latham & Watkins LLP

SEC and FinCEN’s Proposed AML Rule Could Increase Compliance Burden on Investment Advisers

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RIAs and ERAs may soon be required to implement procedures to verify their clients’ identities. On May 13, 2024, the Securities and Exchange Commission (SEC) and the US Department of the Treasury’s Financial Crimes...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

Royer Cooper Cohen Braunfeld LLC

SEC & FinCEN Propose Customer Identification Program Requirements

A press release was recently issued describing a significant joint proposal by the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The proposal...more

Ballard Spahr LLP

Treasury Issues Broad National Strategy for Combatting Illicit Financing

Ballard Spahr LLP on

Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more

Goodwin

FinCEN (and SEC) Propose New Customer Identification Program Rule With Minimal Expected Impact on Private Fund Sponsors

Goodwin on

On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a...more

K2 Integrity

[Webinar] AML/CFT Rules for Investment Advisers - June 12th, 9:30 am PT

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On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

Morgan Lewis

FINCEN’s AML Proposal: An Overview for Investment Advisers

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Earlier this year, the US Department of the Treasury’s (Treasury’s) Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposal) that would subject investment advisers to anti-money...more

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