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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,...