Yesterday, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published responses to three frequently asked questions (“FAQs”) regarding customer due diligence requirements for “covered financial institutions” (
Continue Reading FinCEN Issues FAQs Regarding Customer Due Diligence Requirements
In the last decade, traditional financial institutions such as banks and broker-dealers have faced increased scrutiny from federal regulators and prosecutors related to the adequacy of their anti-money laundering (AML)
Continue Reading AML Compliance Scrutiny of Virtual Currency Services in 2020 and Beyond
On Feb. 10, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published administrative ruling FIN-2020-R001, to clarify requirements of financial institutions reporting on currency transactions
On Oct. 22, 2019, the U.S. House of Representatives, in a 249 to 173 vote, passed H.R. 2513, known as the “Corporate Transparency Act of 2019.” The Corporate
Continue Reading U.S. House Passes Bill That Would Require Disclosure of Beneficial Owners of U.S. Corporations and Limited Liability Companies
On Oct. 11, 2019, the Financial Crimes Enforcement Network (FinCEN), the U.S. Commodity Futures Trading Commission (CFTC), and the U.S. Securities and Exchange Commission (SEC), published a Joint Statement on
Continue Reading CFTC, FinCEN and SEC Issue Joint Statement Reminding Persons in Digital Assets Space of Obligations Under Bank Secrecy Act
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
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
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
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
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