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 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 Requirements
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
On March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama found the Corporate Transparency Act (CTA or Act) unconstitutional on the
Continue Reading District Court Declares Corporate Transparency Act Unconstitutional
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 Requirements
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 Information
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 Requirements
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 Date
Effective Jan. 1, 2024, the Corporate Transparency Act (CTA) will require certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) to
Continue Reading FinCEN Extends Beneficial Ownership Reporting Deadline for Newly Formed Companies
On Oct. 23, 2023, FinCEN published an NPRM that identifies international CVC mixing as “a class of transactions of primary money laundering concern,” and finds that imposing additional recordkeeping and
Continue Reading FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing