FinCEN Expands Geographic Targeting Orders

August Geographic Targeting Orders Cover Funds Transfers and Hawaii Luxury Residential Real Estate   On August 22, 2017, the Financial Crimes Enforcement Network (FinCEN) issued revised Geographic Targeting Orders (GTOs) designed to combat money laundering and related financial crimes in select U.S. residential real estate markets. The GTOs further expand the scope of GTOs issued in January 2016, expanded in July 2016, and renewed in February 2017. In tandem with the August GTOs, FinCEN issued an Advisory to Financial Institutions and Real Estate Firms and Professionals (the “Advisory”) and FAQs. This Business Update outlines the key provisions of the August GTO. For information about this Business Update or MassPoint’s related… Read More

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FinCEN Expands Geographic Targeting Orders to Include Funds Transfers and Hawaii Real Estate

On August 22, 2017, the Financial Crimes Enforcement Network (FinCEN) issued revised Geographic Targeting Orders (GTOs) designed to combat money laundering and related financial crimes in select U.S. residential real estate markets. The GTOs further expand the scope of GTOs issued in January 2016, expanded in July 2016, and renewed in February 2017. In tandem with the August GTOs, FinCEN issued an Advisory to Financial Institutions and Real Estate Firms and Professionals (the “Advisory”) and FAQs.

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Proposed Rule Requires Banks to Collect Beneficial Ownership Information

PDF Download   Key Points Properly understood, “bank secrecy,” in the U.S. legal and regulatory context, facilitates disclosure; it does not afford secrecy. The proposed rule’s customer due diligence requirements fit within the U.S. Bank Secrecy Act/Anti-Money Laundering framework. The beneficial ownership requirement of the proposed rule, if adopted in final form, would to an extent align U.S. customer due diligence mandates with the beneficial ownership provisions of the FATF Recommendations, as revised in 2012. If adopted in final rule form, the proposed rule will take effect as a final rule one year after its effective date. Publication Information: Hdeel Abdelhady, Butterworths Journal of International Banking and Financial Law, November… Read More