On July 22, 2019, the federal bank regulatory agencies and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “Agencies”), issued a Joint Statement on Risk-Focused Bank
Continue Reading Joint Statement Emphasizes Risk-Focused Approach to Examinations of Banks’ BSA/AML Compliance Programs
Greenberg Traurig
Florida Creates Blockchain Task Force to Study Benefits of Blockchain Technology
On May 23, 2019, Florida Gov. Ron DeSantis signed SB 1024 (Florida Blockchain Bill) into law to establish the Florida Blockchain Task Force (Blockchain Task Force) within the Florida Department…
Continue Reading Florida Creates Blockchain Task Force to Study Benefits of Blockchain Technology
FinCEN Issues Guidance on Application of Regulations to Certain Business Models Involving Convertible Virtual Currencies
On May 9, 2019, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) issued “interpretive guidance” addressing how FinCEN’s money services business (MSB) regulations apply to…
Continue Reading FinCEN Issues Guidance on Application of Regulations to Certain Business Models Involving Convertible Virtual Currencies
Regulators Weigh in on Digital Assets, Tokens, Securities, and Derivative Instruments Used in ICOs
The rise of blockchain technology ventures raising money preternaturally through initial coin offerings and token generation events (collectively, ICOs) is a capital formation disruptor, one which has and will continue…
Continue Reading Regulators Weigh in on Digital Assets, Tokens, Securities, and Derivative Instruments Used in ICOs
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…
Continue Reading 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
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…
Continue Reading High-End, Cash-Only Real Estate Sales in Six Major Metropolitan Areas Remain Subject to Mandatory AML Reporting Requirements
OCC Consideration of Special Purpose Fintech Charters Draws Rapid Reaction for State Banking Regulators
On Dec. 2, 2016, the Office of the Comptroller of the Currency (OCC) published a preliminary proposal to create a national bank charter for financial technology companies (fintech). The OCC’s…
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…
Continue Reading 10 TRENDS: Getting Better All the Time
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…
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
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,…
Continue Reading FinCEN Finalizes Customer Due Diligence Rule