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FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals
On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate....
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FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations
Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money...
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FDIC Issues Notice of Proposed Regulations for Enhanced Recordkeeping for...
On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept...
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Corporate Transparency Act Litigation Update: Eleventh Circuit Hears...
Various industry groups have filed lawsuits in multiple federal districts challenging the constitutionality of the Corporate Transparency Act (“CTA”). The first such suit, filed in the Northern...
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FinCEN Reports Check Fraud Amounting to $688 Million Over Six Month Period
The Financial Crimes Enforcement Network (“FinCEN”) issued last month an in-depth report on check fraud stemming from mail theft (“Report”). This is a pernicious and expanding problem. The Report...
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FinCEN Withdraws Designation of ABLV Bank as Foreign Financial Institution...
A Gesture Providing Limited Solace to a Now-Defunct Bank Riga, Latvia Six years ago, in early 2018, we blogged about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s...
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Bank Policy Institute Critiques Notice of Proposed Rulemaking to Modernize...
The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union...
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Halkbank Faces Prosecution: U.S. Court of Appeals Denies Sovereign Immunity
On October 22, 2024, the U.S. Court of Appeals for the Second Circuit ruled that Türkiye Halk Bankası A.Ş. (“Halkbank”), owned by the Republic of Turkey, can be prosecuted for allegedly helping Iran...
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FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML...
Card Club Will Pay $900,000 and Undertake AML Program Review The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the...
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State Fair Access and Debanking Laws Bring Country’s Political and Cultural...
New State Laws Create Tension with Federal AML Requirements An increasing number of states have either enacted or are considering enacting legislation requiring financial institutions to provide...
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