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Christopher M. Paridon

All Things FinReg

LATEST REGULATORY DEVELOPMENTS IMPACTING
THE FINANCIAL SERVICES INDUSTRY

Recent FinCEN UBO Regulations May Inform Compliance Requirements for Trade-Related Agencies

October 10, 2022
The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury issued a final rule on September 29, 2022, implementing the bipartisan Corporate Transparency Act’s beneficial ownership information reporting provisions. What’s noteworthy is that FinCEN used this as an opportunity to expand the definition of beneficial ownership to include any individual who exercises substantial control over the reporting company.
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Topics: Anti-Money Laundering, FinCEN, FinTech

Agencies Emphasize Risk-Based Due Diligence Approach for Charities and Nonprofits

By Kenneth J. Nunnenkamp and Martin Hirschprung
// November 20, 2020
The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to view the “considerations” as anything but.
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Topics: Anti-Money Laundering, Banking, BSA, FDIC, FinCEN, NCUA, OCC

FinCEN Expands AML, Customer Identification Programs, and Beneficial Ownership Requirements to Banks Lacking a Federal Functional Regulator

By Martin Hirschprung
// September 24, 2020
The Financial Crimes Enforcement Network (FinCEN) issued a final rule that requires minimum standards for anti-money laundering (AML) programs for banks lacking a federal functional regulator (the Federal Reserve Board, OCC, FDIC, OTS, NCAU, and SEC), i.e., banks and similar financial institutions that are subject only to state regulation and supervision, and certain international banking entities (collectively, “covered banking entities”).
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Topics: Anti-Money Laundering, Banking, BSA, FDIC, Federal Reserve, FinCEN, OCC, Regulation, Regulatory, Supervision and Examination
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