Page 6 - Customer Identification Program News Today

On February 14, 2023, both the American Bankers Association (ABA) and the Bank Policy Institute (BPI) submitted comments to the Financial Crimes Enforcement Network (FinCEN) on FinCEN’s...

U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds),1 and their U.S. general partners, sponsors, and managers (Advisers), are not directly...

Regulations require that all CIPs state how the financial institution intends to verify the information that accounts applicants have proffered. The identity verification procedures can include the use of documentary evidence, non-documentary evidence, or a mixture of the two.

A Deep Dive Into FinCEN’s Latest Proposals Under the CTA - On December 16, the Financial Crimes Enforcement Network (“FinCEN”) issued a 54-page notice of proposed...

Credit unions should take the time to ensure your house is in order and fully compliant in every area before the year’s end. This will help prepare for new developments, rulings,...

The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) recently announced enforcement actions that reflected sweeping, and previously...

Commodity Futures Trading Commission, CFTC against a decentralized autonomous organization alleged certain automated crypto transactions conducted on a software protocol controlled and managed by a DAO was required to comply with the same registration requirements.

Privacy, both financial and personal, is a key component of life in a free society. Unlike in totalitarian or authoritarian regimes, individuals in free societies have a private sphere free of government involvement, surveillance, and control. The United States Constitution’s Bill of Rights, particularly the Fourth, Fifth, and Ninth Amendments, together with structural federalism and separation of powers protections, is designed to further that end by protecting individual rights. The current ...

Two recent federal enforcement actions—announced the same day—have underlined the need for crypto companies to carefully consider their anti-money laundering (AML) obligations or else...

Fraud has evolved to defeat existing federal Customer Identification Program requirements. It’s time for regulators to modernize them.