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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

Ballard Spahr LLP

Navigating FinCEN’s Actions on Huione Group: Strengthening Defenses Against Money Laundering

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On May 1, 2025, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) regarding the Huione Group, a foreign financial institution located in Cambodia. This proposal, enacted under...more

Brooks Pierce

Corporate Transparency Act: FinCEN and the Treasury Announce Nonenforcement for Domestic Reporting Companies

Brooks Pierce on

Following announcements from the Financial Crimes Enforcement Network (“FinCEN”) on February 27, 2025, and the United States Department of the Treasury (the “Treasury”) on March 2, 2025, it would appear that beneficial...more

Weintraub Tobin

Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule...

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On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related...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

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

Vedder Price

FinCEN Issues Proposed Rule to Enhance Financial Institutions’ AML/CFT Programs

Vedder Price on

On June 28, 2024, in an effort to bolster financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs, the U.S. Department of the Treasury’s Financial Crimes Enforcement...more

K2 Integrity

AML/CFT Rules for Investment Advisers

K2 Integrity on

On 12 June 2024, K2 Integrity and Schulte Roth & Zabel hosted a webinar discussing new regulatory obligations anticipated under proposed rules for investment advisers (IAs), timelines for finalization and compliance, and how...more

BCLP

SEC and FinCEN Propose Rules to Impose Customer Identification Program Obligations on Certain Investment Advisers

BCLP on

On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more

McGlinchey Stafford

Rescheduling Marijuana FAQs: How Do I Submit Comments on DEA’s Proposed Rules?

McGlinchey Stafford on

On May 16, 2024, the U.S. Drug Enforcement Administration (DEA) released the proposed rule (Proposed Rule) to reschedule marijuana from Schedule I to Schedule III under the Controlled Substances Act (CSA). The Office of Legal...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

Dorsey & Whitney LLP

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

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Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Falcon Rappaport & Berkman LLP

FinCEN’s Anti-Money Laundering Regulations for Residential Real Estate Transfers

To crack down on money-laundering in the U.S. residential real estate market, the Financial Crimes Enforcement Network (“FinCEN”) has proposed new reporting requirements for certain real estate transactions. Specifically, the...more

Stark & Stark

Proposed AML Suspicious Activity Rule

Stark & Stark on

On February 13, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule to combat criminals and foreign adversaries from exploiting the U.S. financial system through investment...more

BakerHostetler

Stablecoin Pilot Announced; Crypto Market Data Published; FinCEN Proposal to Combat Crypto Mixing; EU Bank Addresses DAOs; Hacking...

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Banks Complete Stablecoin Pilot, Crypto Indices and Web3 Solutions Launch - According to recent reports, a major German bank and an affiliate of a major British bank have completed a pilot in which stablecoin swaps were...more

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing

On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) taking aim at convertible virtual currency (CVC) mixing transactions,...more

Foley Hoag LLP

Corporate Transparency Act Update: FinCEN Proposes Extending CTA Reporting Deadline for Companies First Created/Registered in 2024

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On September 27, 2023, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) to extend the deadline — from 30 days to 90 days — for domestic and foreign...more

Morgan Lewis

Emerging Financial Crime Trends, Payment Fraud, and Risk Mitigation: How Banks Can Be Prepared

Morgan Lewis on

Consumers’ worldwide adoption of instant, contactless transactions has provided an opportunity for some to take advantage of loopholes and weaknesses in digital systems. Peer-to-peer (P2P) payments fraud, synthetic...more

Herbert Smith Freehills Kramer

FinCEN Considers New Anti-Money Laundering Reporting Requirements For All-Cash Real Estate Transactions

The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a proposed rule that would address the...more

King & Spalding

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

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After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

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In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Foley & Lardner LLP

FinCEN Announces Proposed Rule Aimed at Closing Anti-Money Laundering Regulatory Gaps for Certain Convertible Virtual Currency and...

Foley & Lardner LLP on

On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would require banks and money service businesses (MSBs) “to submit reports, keep records, and verify the...more

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