Private Equity has been siting on the fringes of Anti-money laundering regulation for many years. It’s still illegal to be involved in money laundering and fund managers should be taking some steps to protect themselves and to identify problems. There’s just no set script. FinCEN is supposedly working on a new rule. In the meantime, [...]
Tag Archives: FinCEN
Changes Coming With Anti-Money Laundering Requirements
James H. Freis, Jr., Director of the Financial Crimes Enforcement Network, let us know that his agency is working on anti-money laundering requirements for investment advisers. At a November 15, 2011 speech at the American Bankers Association/American Bar Association’s Money Laundering Enforcement Conference he highlighted many of the issues of money-laundering in the various financial [...]
Anti-Money Laundering Obligations For Private Funds
The Financial Crimes Enforcement Network, Treasury’s financial intelligence unit has been trying to impose anti-money laundering obligations on private funds for years. On September 26, 2002, FinCENissued a notice of proposed rulemaking, proposing to require unregistered investment companies to establish and implement anti-money laundering programs. (Anti-Money Laundering Programs for Unregistered Investment Companies, 67 FR 60617 [...]
Egypt, Mubarak and Politically Exposed Persons
Egypt’s top prosecutor requested the freezing of the foreign assets of ousted president Hosni Mubarak and his family. I expect that is one step in trying to figure out how much of Mubarak’s fortune was derived from corruption. I’ve read reports that his assets could be worth $3 billion and upwards of $70 billion. That [...]
New Anti-Money Laundering Guidance
Money Laundering is bad and financial institutions need to have internal controls policies, procedures and processes to identify higher-risk accounts and monitor the activity. At the core of an anti-money laundering program is that an institution must know its customers and the risks presented by its customers. The program becomes more difficult when the customer [...]
FinCEN and Address Confidentiality Programs
How do you open a bank account when you are hiding from domestic violence? The rules implementing the Bank Secrecy Act require a financial institution to implement a Customer Identification Program that includes procedures that enable it to form a reasonable belief that it knows the true identity of its customers. The rules also require [...]
Financial Crimes Enforcement Network 2008 Annual Report
The Financial Crimes Enforcement Network 2008 Annual Report (.pdf) has been released. Outcome Goal 1: Financial systems resistant to abuse by money launderers, terrorists and their financial supporters, and other perpetrators of financial crime Outcome Goal 2: Detection and deterrence of money laundering, terrorism financing, and other illicit activity. Outcome Goal 3: Efficient management, safeguarding, [...]
Opening Securities and Futures Accounts from an OFAC Perspective
The Office of Foreign Assets Control published new guidance specific to the securities industry on 11/06/2008: Opening Securities and Futures Accounts from an OFAC Perspective A strong OFAC compliance program consists of procedures that are similar to those found in a brokerage firm’s Customer Identification Program (“CIP”). Firms should use risk-based measures for verifying the [...]
Effects of FinCEN’s Withdrawal of Rule-Making on Anti-Money Laundering
Last week, FinCEN withdrew a proposed rulemaking for anti-moneylaundering procedures for unregistered investment companies. [See: FinCEN Withdraws Proposed Rulemaking for Unregistered Investment Companies] FinCEN warned that they have not abandoned plans for rule-making. They merely felt that after six years the notice had gone stale. FinCEN may come out with AML program rule proposal, but would [...]
FinCEN Rulemaking
The Financial Crimes Enforcement Network has put up a page dedicated to their pending rulemakings: FinCEN Pending Rulemakings.
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