On May 26, 2020, the Financial Crimes Enforcement Network (FinCEN) published a notice to renew the Office of Management and Budget (OMB) control numbers assigned to Suspicious Activity Reporting (SAR) requirements. Although no changes to the requirements themselves are proposed, FinCEN notice in the Federal Register proposes to revise its estimate of the burden to
FinCEN Renews Geographic Targeting Orders on Certain Residential Real Estate Purchases for Additional Six Months
On May 8, 2020, the Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to obtain and verify identifying information for the natural persons behind shell companies used to make all-cash purchases of residential real estate with values equal to or greater than $300,000. The GTOs only
FinCEN Provides Relief to Application of Beneficial Ownership Requirements to Certain CARES Act Loans and Suspends Implementation of CTR Filing Changes
In April 3, 2020 guidance, the Financial Crimes Enforcement Network (FinCEN) provided limited relief from beneficial ownership verification requirements for federally-insured depository institutions and federally insured credit unions that offer Paycheck Protection Program (PPP) loans to existing customers under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). It also has suspended implementation
Caroline Brown Joins Crowell & Moring
Former U.S. Treasury and Justice Department Lawyer Strengthens Anti-Money Laundering, Economic Sanctions, and CFIUS Practices
Washington, D.C. — February 20, 2020: Crowell & Moring is bolstering its anti-money laundering, economic sanctions, and CFIUS practices with the addition of Caroline Brown, former attorney in the U.S. Department of the Treasury and the U.S. Department of
FinCEN Identifies Iran as Money Laundering Threat While OFAC Announces New Mechanism to Facilitate Humanitarian Assistance There
On Friday, October 25, 2019 the Financial Crimes Enforcement Network (FinCEN) issued a final rule pursuant to Section 311 of the USA PATRIOT Act finding Iran to be a jurisdiction of primary money laundering concern and imposing special measures prohibiting U.S. financial institutions from maintaining correspondent accounts for or on behalf of Iran. Separately on
FinCEN Announces New Global Investigations Division and New Leader for Liaison Division
On August 28, 2019 the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the launch of a Global Investigations Division (GID), which will be led by Matthew Stiglitz, a former Principal Deputy Chief in the Department of Justice’s (DOJ’s) Criminal Division. The GID replaces and expands on FinCEN’s Office of Special Measures (OSM),
FinCEN and Federal Banking Agencies Encourage Innovative Approaches to BSA/AML Compliance
On December 3, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), the National Credit Union Administration, and the Office of the Comptroller of the Currency (together “the agencies”), issued a joint statement encouraging banks
FinCEN Issues Revised GTOs Including Lower Purchase Thresholds and Virtual Currencies
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,
Agencies Issue Joint Statement on Banks’ Resource Sharing and Collaborative Arrangements
On October 3, 2018, the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) (collectively, “the Agencies”) issued a statement addressing instances in which banks can collaborate
FinCEN Grants Rollover and Renewal Exception to Beneficial Ownership Requirement
On September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) granted exceptive relief to “covered financial institutions”—banks, broker-dealers, mutual funds, and introducing brokers in commodities—from the requirement to identify and verify the identity of the beneficial owner(s) of their legal entity customers when those customers open a new account as a result of the following: