News & Analysis as of

Recordkeeping Requirements Beneficial Owner Anti-Money Laundering

Winthrop & Weinstine, P.A.

Client Alert: Corporate Transparency Act (CTA) Reporting Requirements Update

The Financial Crimes Enforcement Network (FinCEN) has reinstated the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA).  Following recent court decisions, the deadline...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

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The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...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

Seward & Kissel LLP

Q&A on FinCEN’s New AML Requirements for Certain Investment Advisers

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more

WilmerHale

Corporate Transparency Act: First Wave of Required Reports Due Starting on March 31, 2024

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As we have previously reported, the Corporate Transparency Act (“CTA”) is a broad anti-money laundering law intended to assist law enforcement in combating illicit financial activity. The CTA’s beneficial ownership reporting...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

Ballard Spahr LLP

FinCEN Proposes BSA Reporting Requirements for Residential Real Estate

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On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more

Perkins Coie

The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024

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Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Walkers

What can we learn from recent enforcement actions in the Cayman Islands?

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Walkers' regulatory partners Lucy Frew and Ian Mason consider the learning points for financial services providers (FSPs) from recent enforcement actions by Cayman regulatory bodies. While financial services and related...more

Goodwin

FinCEN Finalizes Rule Implementing beneficial Ownership Reporting Requirements Under the CTA

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Regulatory Developments - FinCEN Finalizes Rule Implementing Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act - On September 29, FinCEN issued a final rule under the CTA requiring each...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

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Sullivan & Worcester

FFIEC Examination Procedures for the Beneficial Ownership Rule

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The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more

Foodman CPAs & Advisors

Here is what you need to know about the FinCEN’s Final CDD Rule effective May 11, 2018

Covered Financial Institutions (CFI) have until May 11, 2018 to implement and comply with the Financial Crimes Enforcement Network (FinCEN) Final Customer Due Diligence Rule (the CDD Rule). The CDD Rule imposes a new...more

Hogan Lovells

New anti-money laundering regulations: action for pension scheme trustees - Updated December 2017

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Pension scheme trustees should be aware of requirements under new money laundering regulations to record information and, in some cases, to give the information to third parties and to register the information with HMRC. ...more

Hogan Lovells

New anti-money laundering regulations: action for pension scheme trustees

Hogan Lovells on

Pension scheme trustees should be aware of requirements under new money laundering regulations to record information and, in some cases, to give the information to third parties and to register the information with HMRC. ...more

Proskauer - Corporate Defense and Disputes

FinCEN Proposal Looks to Extend AML Requirements to Non-Federally Regulated Banks

On April 25, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, proposed a rule that would require all banks, regardless of whether they are subject to regulation by a...more

K2 Integrity

Five Areas of Focus for the New CDD Rule

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While regulators haven’t yet spelled how the new customer due diligence (CDD) requirements for financial institutions will be implemented, banks, credit unions, securities firms, money services businesses, and casinos should...more

Dorsey & Whitney LLP

The New AML Regulations and Their Impact on Banks—Increased Compliance for Lending Transactions with Legal Entities

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On May 11, 2016, FinCEN published in the Federal Register its long-awaited anti-money laundering (“AML”) rules (the “Final Rules”) governing corporate entities doing business with banks and other financial institutions that...more

The Volkov Law Group

FinCEN Issues New Beneficial Ownership Regulations

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Under the dark cover of the Panama Papers scandal, FinCEN moved quickly to issue its beneficial; ownership regulations. For all of the US regulatory and financial industry bluster, it is about time. The United States stands...more

Ballard Spahr LLP

Recent Investment Management Developments - May 2016

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Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. ...more

Goodwin

FinCEN Issues Final Customer Due Diligence Rule

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The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has expanded the due diligence obligations of certain financial institutions that are subject to a customer identification program requirement under...more

Stinson LLP

New FinCEN Rule Requires Heightened Identification Procedures and Anti-Money Laundering Diligence

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A new Financial Crimes Enforcement Network (FinCEN) rule under the Bank Secrecy Act will require institutions to more specifically identify legal entity customers and increase anti-money laundering diligence. The rule will...more

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