On April 5, 2021, the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed Rulemaking (ANPRM) in the Federal Register seeking public comment on 48 questions with respect to the implementation of the beneficial ownership reporting requirements in the Corporate Transparency Act (CTA) and the implementation of the related database maintenance use and
Beneficial Ownership
Congress Passes the Anti-Money Laundering Act of 2020, Significant Changes to the Bank Secrecy Act Ahead
On January 1, 2021, the Senate followed the House and voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (NDAA). As is typical, the NDAA touched on a wide range of legal areas, including numerous new government contracts requirements, as well as a number of sanctions and export…
FinCEN Issues Revised GTOs Including Lower Purchase Thresholds and Virtual Currencies
By Carlton Greene & Allegra Flamm on
On November 15, 2018, FinCEN issued revised Geographic Targeting Orders (GTOs), once more expanding its scrutiny of “all-cash” purchases (i.e., those without bank loans or other external financing) in the luxury residential real estate market. FinCEN broadened the geographic scope of the orders, lowered the purchase amount threshold for each covered area,…
New Obligation for Belgian Entities to Register Ultimate Beneficial Owners by March 31, 2019
In 2015, the European Union adopted its Fourth Anti-Money Laundering Directive, which imposed on Member States the obligation to establish a register containing the details of the ultimate beneficial owners (UBOs) of corporate and other legal entities within the European Union (the so-called UBO register). By way of the Act of September 18, 2017, the…
Now Available On Demand – Webinar Trade in 2018 – What’s Ahead?
By Frances P. Hadfield & Edward Goetz on
Posted in Anti-Money Laundering (AML), Antidumping/Countervailing Duty (AD/CVD), Bank Secrecy Act (BSA), Beneficial Ownership, Blockchain, Brexit, CAATSA, Committee on Foreign Investment in the U.S. (CFIUS), Customs, EU Customs and Trade Agreements, EU Sanctions, Export Controls, Financial Crimes Enforcement Network (FinCEN), Forced Labor/U.K. Modern Slavery Act, Iran Sanctions, Joint Comprehensive Plan of Action (JCPOA), North Korea Sanctions, Office of Foreign Assets Control (OFAC), Russia Sanctions, Sanctions, Section 232 Investigations, Section 232 Tariffs, Section 301 Investigation, U.K. Trade and Sanctions, U.S. Trade Policy, Venezuela Sanctions
On April 19, Crowell & Moring’s International Trade Attorneys hosted a webinar on “Trade in 2018 – What’s Ahead?”
Please click here to register and view the webinar on demand.
Summary
From the Section 232 national security tariffs on steel and aluminum imports to the ongoing NAFTA re-negotiation, the Trump administration is seeking to implement…
PODCAST: Anti-Money Laundering and the New Beneficial Ownership Rule — C&M’s Trump: The First Year Series
By Carlton Greene on
Posted in Beneficial Ownership
What does the new beneficial ownership rule mean for lenders and other businesses? As part of our “Trump: The First Year” series, International Trade Group partners Carlton Greene and Cari Stinebower sit down with Commercial Finance & Lending Senior Counsel Scott Lessne to discuss the new rule. Prior to joining the firm in…
FinCEN’s Final Rule on Beneficial Ownership and the Administration’s New Initiatives on Financial Transparency: What You Need to Know
By Carlton Greene, Kelly T. Currie, Jim Flood & Dalal Hasan on
Posted in Beneficial Ownership
On May 6, 2016, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a final rule (the “Final Rule”) requiring banks, brokers or dealers in securities, mutual funds, futures commission merchants, and introducing brokers in commodities (collectively, “covered financial institutions”) to obtain and record beneficial ownership information as part of their anti-money laundering…