The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has long recognized non-financed (i.e., “all-cash”) transfers of residential real estate as susceptible of money laundering because these methods
Continue Reading FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting RequirementsClaudio 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 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).
FinCEN Publishes Final Rule on Access to Beneficial Ownership Information
On Dec. 22, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule (Access Rule) establishing the parameters for authorized access to BOI reported…
Continue Reading FinCEN Publishes Final Rule on Access to Beneficial Ownership InformationCorporate Transparency Act Takes Effect with Beneficial Ownership Reporting Requirements
Starting Jan. 1, 2024, the Corporate Transparency Act and its implementing regulations mandate that certain U.S. legal entities and foreign entities registered to do business in the United States (collectively…
Continue Reading Corporate Transparency Act Takes Effect with Beneficial Ownership Reporting RequirementsFinCEN Updates Frequently Asked Questions on Beneficial Ownership Reporting Rule Ahead of Jan. 1, 2024, Effective Date
Starting Jan. 1, 2024, the CTA mandates that certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) report certain BOI…
Continue Reading FinCEN Updates Frequently Asked Questions on Beneficial Ownership Reporting Rule Ahead of Jan. 1, 2024, Effective DateNew Florida Legislation Proposes Notification Requirements for Certain Financial Institutions When They Terminate, Suspend, or Take Similar Action to ‘Restrict’ Customer Account Access
On Nov. 20, 2023, Florida Rep. Bob Rommel (R-Naples) introduced Florida House Bill 585, which proposes to require certain financial institutions operating in Florida to file a “termination-of-access report” with…
Continue Reading New Florida Legislation Proposes Notification Requirements for Certain Financial Institutions When They Terminate, Suspend, or Take Similar Action to ‘Restrict’ Customer Account AccessCorporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting Requirements
The Corporate Transparency Act of 2019 (CTA), enacted as part of the Anti-Money Laundering Act of 2020, requires, for the first time, that certain U.S. legal entities and foreign entities…
Continue Reading Corporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting RequirementsFederal Banking Agencies Propose New Rules to Strengthen Capital Requirements for Large Banks
On July 27, 2023, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued an interagency…
Continue Reading Federal Banking Agencies Propose New Rules to Strengthen Capital Requirements for Large BanksThe 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties
On March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank, Santa Clara, CA (SVB) and appointed the Federal Deposit Insurance Corporation (FDIC) receiver of…
Continue Reading The 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties
On March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank, Santa Clara, California (SVB) and appointed the Federal Deposit Insurance Corporation (FDIC) as receiver…
Continue Reading The 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesFinCEN Proposes Rule on Access to Beneficial Ownership Information
On Dec. 15, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking implementing the provisions of the Corporate Transparency Act that…
Continue Reading FinCEN Proposes Rule on Access to Beneficial Ownership Information