On Dec. 6, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on potential requirements under the Bank Secrecy Act (BSA) for certain persons involved in real estate transactions to collect, report, and retain information.

Click here to read the full GT Alert.

Tags: AML and FinCEN Compliance, ANPR, anti-money laundering, Bank Secrecy Act, FinCEN, GT Insight, real estate, transactions
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Kyle R. Freeny Kyle R. Freeny

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations,

…

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations, and anti-money laundering (AML) and international corruption matters.

Kyle was one of 19 prosecutors selected by Robert S. Mueller III to conduct the high-profile investigation into alleged Russian election interference, coordination between Russian officials and the Trump campaign, and related matters. As Assistant Special Counsel, Kyle played a lead role in federal tax and bank fraud investigations, as well as a money laundering investigation into the funding of Russian intelligence cyber intrusions during the 2016 Presidential election using cryptocurrency.

While at the Department of Justice, Kyle was involved in investigations relating to major international money laundering and corruption matters, including matters involving the Bank Secrecy Act (BSA), Foreign Corrupt Practices Act (FCPA), and foreign banking and corruption laws designated as predicates to U.S. money laundering charges. Kyle has considerable experience handling cross-border issues and coordinating with foreign law enforcement authorities and U.S. and foreign regulators on complex transnational financial cases.

Kyle has also represented dozens of federal agencies in high-profile litigation, including the Office of Foreign Assets Control (OFAC), the Department of Defense, and the Federal Financing Bank. Kyle has appeared before federal trial courts across the country.

‡ Admitted in California. Practice in the District of Columbia limited to matters and proceedings before Federal courts and Agencies.

Read more about Kyle R. FreenyKyle's Linkedin Profile
Show more Show less
Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

Read more about Marina Olman-Pal
Show more Show less
Photo of Claudio J. Arruda Claudio J. Arruda

Claudio J. Arruda advises domestic and international financial services firms and institutions, including banks, broker-dealers, Fintech companies, and investment advisory firms on a broad range of regulatory issues, as well as general corporate matters. He represents these institutions on matters related to the…

Claudio J. Arruda advises domestic and international financial services firms and institutions, including banks, broker-dealers, Fintech companies, and investment advisory firms on a broad range of regulatory issues, as well as general corporate matters. He represents these institutions on matters related to the applicability and compliance with state and federal banking, and consumer laws and regulations.

Claudio also advises a wide range of investment advisers on all aspects of securities regulatory compliance, particularly including new and existing SEC rules, and has experience advising clients on corporate governance and general corporate matters.

In addition, Claudio represents public and private corporations in negotiating cross-border financing projects. He also has experience assisting in securities enforcement matters and FCPA-related investigations at the U.S. Securities and Exchange Commission (SEC).

Read more about Claudio J. ArrudaClaudio's Linkedin Profile
Show more Show less
Related Posts
Regulatory&Compliance_Proposal
2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part Two of Two)
November 21, 2024
RealEstateFunds_Proposal
2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part One of Two)
August 23, 2024
shutterstock_551895805
FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting Requirements
March 5, 2024