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 to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).1 FinCEN has noted that, as of April 30, 2024, over a million
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 to FinCEN. The Access Rule is the second of three rulemakings implementing the Corporate Transparency Act (CTA), a law designed to increase transparency in the
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 to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), as implemented by FinCEN’s September 2022 Final Rule.1 Ahead of
On April 18, 2023, Department of Commerce Assistant Secretary for Export Enforcement Matthew Axelrod issued a memorandum (Memorandum) that, while primarily focused on enforcement of export control restrictions, offered some noteworthy insights into the Bank Secrecy Act’s newly overhauled whistleblower program. That whistleblower program, originally enacted as part of the Anti-Money Laundering Act of
On July 14, 2022, the U.S. House of Representatives passed bipartisan legislation that, if passed by the Senate and signed into law, would expand the types of institutions required to comply with AML requirements under the Bank Secrecy Act (BSA). The Establishing New Authorities for Business Laundering and Enabling Risks to Security (ENABLERS) Act could
On Dec. 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking to implement the beneficial ownership information reporting provisions of the Corporate Transparency Act.
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In December 2021, the UK Financial Conduct Authority (FCA) published a consultation to set a higher standard of consumer protection in retail financial markets, an endeavor which began in July 2018. At the core of the proposed new rules is a new Principle for Businesses: “A firm must act to deliver good outcomes for
To expedite decisions to prevent or stop consumer harm, the Financial Conduct Authority (FCA) has implemented a controversial change to its decision-making procedures. The change forms part of the FCA’s wide-ranging “Transformation Programme” that seeks (in summary) to make the regulator smarter, more proactive and more agile.
On Oct. 23, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (FRB) (FinCEN and the FRB collectively, the Agencies), issued a joint notice of proposed rulemaking (Proposed Rule) that would amend the Recordkeeping Rule and Travel Rule regulations issued under the
On Feb. 7, 2019, the UK’s National Crime Agency (NCA) confirmed that it had obtained account forfeiture orders over money held in bank accounts in the name of the former Moldovan prime minister’s son, Vlad Luca Filat.
Part III of our ‘Prove It or Lose It’ series anticipated the use of UK law enforcement authorities’