Category Archives: Financial Crimes Enforcement Network

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New Bill Introduced in the U.S. Senate to Require the Disclosure of Ultimate Beneficial Owners of Corporations and LLCs Formed or Registered in the United States

On August 2, 2017, United States Senators Marco Rubio (R-FL) and Ron Wyden (D-OR) jointly introduced Senate Bill 1717, entitled the “Corporate Transparency Act of 2017” (the “Act”).  The Act was referred to the U.S. Senate Committee on Banking, Housing and Urban Affairs.  The Act would amend Title 31 of the United States Code, to … Continue Reading

High-End, Cash-Only Real Estate Sales in Six Major Metropolitan Areas Remain Subject to Mandatory AML Reporting Requirements

On Feb. 23, 2017, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) extended by an additional six months its existing Geographic Targeting Orders (GTOs) that require U.S. title insurance companies, their subsidiaries and agents (collectively, the Title Insurance Companies) to identify the natural persons behind shell companies used to pay … Continue Reading

10 TRENDS: Getting Better All the Time

When Jennifer Shasky-Calvery, at the time the director of the Financial Crimes Enforcement Network (FinCEN), addressed attendees at G2E 2013, she brought a stern message to the industry. She called for a complete culture change in the industry with a dedication to rooting out financial crimes… or else. Since then, Bank Secrecy Act (BSA) and anti-money … Continue Reading

U.S. Treasury Department Expands its ‘Real Estate GTOs’ to Require Title Insurance Companies and Their Agents To Report the Ultimate Beneficial Owners of Entities Used To Buy Residential Real Estate in All-Cash Purchases in Six Metropolitan Areas, Including all of New York City, South Florida and Portions of California and Texas

On July 27, 2016, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) issued a press release announcing new Geographic Targeting Orders (GTOs) applicable to certain U.S. title insurance companies and their subsidiaries and “agents” (collectively, the Targeted Title Insurance Companies). The new GTOs go well beyond those that were initially … Continue Reading

FinCEN Finalizes Customer Due Diligence Rule

May 6, 2016, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) finalized regulations that will require banks, securities broker dealers, mutual funds, futures commission merchants, and introducing brokers in commodities (collectively, Covered Institutions) to identify and perform due diligence on the ultimate beneficial owners and control persons of any legal … Continue Reading

OCC Issues New Guidance and Policies on Enforcement Actions and Civil Monetary Penalties Against Institutions and Individuals

The Office of the Comptroller of the Currency (“OCC”) recently released new guidance on the process it uses when considering enforcement actions against banking institutions and individuals for potential non-compliance with Bank Secrecy Act (“BSA”) compliance program requirements and anti-money laundering (“AML”) rules.  At the same time, the OCC also issued a revised policy for … Continue Reading

FinCEN Issues Second South Florida GTO in Less Than Three Months

Today, the Financial Crimes Enforcement Network (FinCEN), working in conjunction with U.S. Internal Revenue Service – Criminal Investigation (IRS-CI) and the United States Attorney’s Office for the Southern District of Florida, issued a Geographic Targeting Order (GTO) for Miami-Dade and Broward counties. The GTO applies to check cashing business and requires check cashers to keep … Continue Reading

FinCEN Releases A Geographic Targeting Order Concerning Currency Reporting Laws in Certain Areas of Miami-Dade County

On April 21, 2015, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN), working in conjunction with U.S. Immigration and Customs Enforcement’s Homeland Security Investigations (HSI) and the South Florida Money Laundering Strike Force, released a rarely-issued Geographic Targeting Order (GTO) for certain areas of Miami-Dade County. The GTO requires certain … Continue Reading
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