Overview The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released new Frequently Asked Questions (“FAQs”) in October 2025 clarifying several aspects of Suspicious Activity Report (“SAR”) filing … Continue reading FinCEN FAQ Eases SAR Documentation Burden – But Raises the Bar on Risk-Based Judgment
On February 27, 2017, the Financial Crimes Enforcement Network (FinCEN) announced the assessment of a $7 million civil money penalty (CMP) against Merchants Bank of California (“Merchants”) in Carson, CA, … Continue reading FinCEN Penalizes California Bank for AML Violations
FinCEN has issued the second edition of SAR Stats, FinCEN’s annual review of aggregated Suspicious Activity Report (SAR) filing activity and announced the introduction of Interactive SAR Stats. FinCEN developed … Continue reading FinCen Releases Annual Review of SAR’s Data
The Basel Institute on Governance recently published the Basel Anti-Money Laundering (AML) AML Index for 2015. The report provides an annual risk rating of money laundering and terrorist financing by ranking countries … Continue reading Basel Institute Publishes the 2015 Basel AML Index
The Financial Crimes Enforcement Network (FinCEN) has finally reproposed a rule requiring investment advisers that are required to be registered with the U.S. Securities and Exchange Commission (SEC) to establish … Continue reading AML Programs to be Required for Federal Investment Advisers
The U.S. Department of the Treasury (“Treasury Department”) submitted its Semiannual Regulatory Agenda for review by The Office of Management and Budget (“OMB”) in April 2015. The semiannual regulatory agenda … Continue reading FinCEN Re-Proposes AML Rule for Investment Advisers
The Financial Crimes Enforcement Network (FinCEN) is proposing new rules under the Bank Secrecy Act (BSA) to clarify and strengthen customer due diligence (CDD) requirements for banks, broker-dealers, mutual funds, … Continue reading New Proposed AML Customer Due Diligence Requirements
Overview The Foreign Account Tax Compliance Act (“FATCA”) has resulted in significant changes in the reporting and withholding requirements of financial institutions, including broker-dealers and investment advisers that represent foreign … Continue reading Treasury Regulations Implemented to Address FATCA Impact Broker-Dealers and Investment Advisers
The SEC has recently issued a No-Action Letter that extends the ability for a broker-dealer to treat an investment adviser as if it were subject to an Anti-Money Laundering Program (AML … Continue reading SEC Extends Broker-Dealer Reliance on CIPs of Investment Advisers
January 2010 FINRA Rule Changes Related To Anti-Money Laundering and Business Continuity Plans With the New Year having arrived, it is important to note that FINRA has already commenced … Continue reading FINRA AML & BCP Rule Changes