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FinCEN Commences Rulemaking Process for Implementation of Corporate Transparency Act Requiring Disclosure of Beneficial Ownership Information

USA - April 26 2021 On April 5, 2021, the Financial Crimes Enforcement Network, a bureau of the United States Department of the Treasury (“FinCEN” and “Treasury,”…

Melissa G.R. Goldstein, Kyle B. Hendrix, Betty Santangelo

Shareholder Activism in US Regulated Industries

USA - March 23 2021 Companies in highly regulated industries have historically been subjected to relatively few campaigns and demands from shareholder activists…

Brandon S. Gold, Eleazer Klein

FinCEN Issues First-Ever Enforcement Guidelines and Federal Banking Agencies Update Enforcement Guidance

USA - February 1 2021 The Financial Crimes Enforcement Network ("FinCEN") issued a statement describing its approach to enforcing the Bank Secrecy Act ("BSA") and its…

Melissa G.R. Goldstein, Betty Santangelo, Gary Stein, Hannah Thibideau, Nicholas A. Wilson

Passage of Anti-Money Laundering Act of 2020 Includes Comprehensive BSA/AML Reform Measures

USA - January 7 2021 On Dec. 31, 2020, as part of the National Defense Authorization Act (“NDAA”), Congress enacted the Anti-Money Laundering Act of 2020 (“AML Act”) and…

Melissa G.R. Goldstein, Donald J. Mosher, Betty Santangelo, Gary Stein, Nicholas Zlevor

OCC Finalizes Rule Clarifying the ‘True Lender’ in Bank/Nonbank Lending Partnerships

USA - October 28 2020 On Oct. 27, 2020, the Office of the Comptroller of the Currency (“OCC”) finalized a rule that clarifies that a national bank or federal savings…

Nicholas A. Wilson