A Texas district court has issued a nationwide preliminary injunction four weeks before a key Jan. 1, 2025, reporting deadline for the Corporate Transparency Act (CTA) that, while in effect
Continue Reading Texas Court Blocks CTA Nationwide 4 Weeks Before Key Reporting DeadlineMarina 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 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.
FinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment Advisers
On Sep. 4, 2024, FinCEN published a final rule (Final Rule) adding certain RIAs and ERAs (collectively, Covered Advisers) to the definition of “financial institution” under the regulations…
Continue Reading FinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment AdvisersFDIC Extends Comment Period for New Requirements for Custodial Accounts
On Nov. 18, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a 45-day extension to the public comment period for its proposed rule making (Proposed Rule) that would establish new…
Continue Reading FDIC Extends Comment Period for New Requirements for Custodial AccountsFDIC Proposes New Requirements for Custodial Accounts
On Oct. 2, 2024, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking (Proposed Rule) designed to strengthen recordkeeping requirements for custodial deposit accounts with transactional features…
Continue Reading FDIC Proposes New Requirements for Custodial AccountsCTA Countdown: Upcoming FinCEN Filing Deadlines
The Corporate Transparency Act (CTA) has been in effect since Jan. 1, 2024, requiring non-exempt U.S. entities and non-exempt foreign entities that are registered to do business in the United…
Continue Reading CTA Countdown: Upcoming FinCEN Filing DeadlinesFinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements
On June 28, 2024, FinCEN issued a Proposed Rule to amend BSA regulations that prescribe the minimum requirements for AML/CFT programs for “financial institutions.” Financial institutions subject to AML/CFT program…
Continue Reading FinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program RequirementsFinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting Requirements
The CTA mandates that, starting on Jan. 1, 2024, certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) disclose certain BOI…
Continue Reading FinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting RequirementsCalifornia Senate Passes State’s Version of Corporate Transparency Act
On Feb. 15, 2024, California Sen. Maria Elena Durazo (D-Los Angeles) introduced Senate Bill 1201 (SB 1201 or the Bill), which would impose new disclosure requirements on California companies. Amended…
Continue Reading California Senate Passes State’s Version of Corporate Transparency ActNew Florida Law Creates House Bill 3 Complaint, OFR Investigation Process, and Expands Applicability to Additional Financial Institutions
On May 2, 2024, Florida Gov. Ron DeSantis held a press conference where he signed Florida House Bill 989 (HB 989 or the Bill) into law. HB 989 amends section…
Continue Reading New Florida Law Creates House Bill 3 Complaint, OFR Investigation Process, and Expands Applicability to Additional Financial InstitutionsFinCEN Proposes Rule to Subject Certain Investment Advisers to Anti-Money Laundering Program, Recordkeeping, and Reporting Requirements under the Bank Secrecy Act
After years of rulemaking efforts, FinCEN issued a Notice of Proposed Rulemaking (Proposed Rule) Feb. 15, 2024, that would subject certain investment advisers to AML/CFT compliance requirements under the BSA.
Continue Reading FinCEN Proposes Rule to Subject Certain Investment Advisers to Anti-Money Laundering Program, Recordkeeping, and Reporting Requirements under the Bank Secrecy Act