Financial Crimes Enforcement Network (FinCEN)

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In advance of the impending January 1, 2024 effective date for the U.S. Treasury Department, Financial Crimes Enforcement Network’s (“FinCEN’s”) beneficial ownership information (“BOI”) reporting requirements, FinCEN has proposed an extension of the reporting deadline for some reporting companies, and issued additional guidance regarding BOI reporting requirements, including a Small Entity Compliance Guide, a …

On March 24, 2023, the Financial Crimes Enforcement Network (“FinCEN”) issued its first set of guidance documents for its beneficial ownership reporting requirements, which take effect on January 1, 2024.

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On June 28, 2022, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert (the “Alert”), urging financial institutions regulated under the Bank Secrecy Act (“BSA”) to remain vigilant of efforts by third parties to evade the extensive U.S. export controls imposed on…

On August 31, 2021, New York Governor Kathy Hochul announced the nomination of Adrienne Harris as the Superintendent of the New York Department of Financial Services – New York’s top financial regulator and a key regulator in the banking, anti-money laundering, fintech, insurance, and cryptocurrency spaces. Harris, whose nomination is still subject to confirmation, has…

On August 10, 2021, the Financial Crimes Enforcement Network (“FinCEN”) and the Commodity Futures Trading Commission (“CFTC”) jointly announced $100 million in civil settlements with five entities responsible for the operations of BitMEX, a foreign peer-to-peer convertible virtual currency (“CVC,” or cryptocurrency) derivatives exchange.  FinCEN said that the settlement represents FinCEN’s first enforcement action against…

Washington – August 6, 2021: Himamauli Das, senior advisor at Crowell & Moring International, LLC, has been named acting director of the Financial Crimes Enforcement Network, the anti-money-laundering unit of the U.S. Treasury Department. Das assumes the role at a time when FinCEN is moving to implement provisions of the Anti-Money Laundering Act of 2020,…

On June 30, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued its first-ever Anti-Money Laundering and Countering the Financing of Terrorism National Priorities (the “Priorities”). FinCEN was required to do this by the Anti-Money Laundering Act of 2020 (“AMLA”), enacted on January 1, 2021, as part of the National Defense Authorization Act of 2021. FinCEN…

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…

On March 9, 2021, the Financial Crimes Enforcement Network (FinCEN) published its first Notice related to one of the many changes made in the Anti-Money Laundering Act of 2020 (the AML Act), passed as part of the National Defense Authorization Act for Fiscal Year 2021, which we wrote about here. FinCEN’s guidance informs financial…

On October 23, 2020, the Federal Reserve Board and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking that would amend the Bank Secrecy Act’s Recordkeeping Rule and Travel Rule regulations. The proposed changes would: (a) lower the threshold for covered cross-border transactions from $3,000 to $250, and (b) extend the…