AML

Unexplained Wealth Orders (UWOs) extend the powers available to UK law enforcement authorities under the Proceeds of Crime Act 2002 (POCA), enabling investigators to ask people who are holding assets,…
Continue Reading Prove It or Lose It! Parts I and II: Unexplained Wealth Orders and Civil Recovery Orders in the United Kingdom

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

In January 2016, the Treasury Department announced “geographic targeting orders” (GTOs) that will require title insurance companies and their agents to obtain representative and ultimate beneficial ownership information when a…
Continue Reading Manhattan and Miami Residential Real Estate Sales – What Are the New Treasury Department Anti-Money Laundering Requirements All About?

On July 23, 2015, the Office of Management and Budget (OMB) completed its review of a proposed regulation submitted to OMB by the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury that, when finalized into a final regulation, would require investment advisers to adopt and implement anti-money laundering (AML) program and file suspicious activity reports (SARs). The clearance by the OMB means a proposed AML program/SAR regulation for investment advisers could be published by FinCEN as early as within the next several weeks. It remains unclear whether such publication would resuscitate the prior FinCEN proposals of over a decade ago which would have required unregistered investment companies and commodities trading advisers to adopt an AML program. 
Continue Reading Proposed AML Program and SAR Reporting Requirements Nearing for Investment Advisers