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FinCEN

Jan 12, 2021

In Defense of the Realm: The NDAA, Money Laundering, and Terrorist Financing

On New Year’s Day, January 1, 2021, the U.S. Senate voted 81 to 13 to override President Trump’s veto of the National Defense Authorization Act (“NDAA”), thus joining the House of Representatives, which had taken similar action four days earlier 322 to 87, so enacting the NDAA into law.» Read More

Dec 11, 2019

Corporations and LLCs: New Federal Beneficial Ownership Disclosure Requires Reporting to FinCEN

On October 22, 2019, the House of Representatives passed the Corporate Transparency Act of 2019 which requires the U.S. Department of the Treasury within one year to issue regulations to “carry out this Act.”

The Act requires each newly formed corporation and each newly formed limited liability company, unless specifically exempt, to file a report with the Financial Crimes Enforcement Network (“FinCEN”) disclosing the beneficial owners of those entities.» Read More

Jul 19, 2018

The Merry Month of May: FinCEN, GDPR, and Financial Institutions

In 1599 the English Elizabethan dramatist Thomas Dekker (1572-1632) saw his play “The Shoemaker’s Holiday” first performed (in London). In Act 3, Scene V of the play, set in a French “neighborhood,” a famed bit of verse is included (relevant to occurrences in the play):

O, the month of May, the merry month of May

So frolic, so gay, and so green, so green, so green!» Read More