Stanley J. Boris

Oct 28, 2024 | datamatters.sidley.com | Joel D Feinberg |David E Teitelbaum |Stanley J. Boris

On October 22, 2024, the U.S. Consumer Financial Protection Bureau (CFPB) issued a final rule under Section 1033 of the Consumer Financial Protection Act of 2010.1 The final rule includes several important changes from the proposed rule. This client alert focuses on those changes. For an analysis of the proposed rule, please see our Sidley Update here.

Jul 8, 2024 | lexology.com | Joel D Feinberg |David E Teitelbaum |Paul Tyrrell |Stanley J. Boris |Kristin S. Teager |Nicole Cary

On June 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a proposed rule (Proposed Rule) to strengthen and modernize financial institutions’ anti-money-laundering and countering the financing of terrorism (AML/CFT) programs.1 The Proposed Rule would amend FinCEN’s regulations to implement minimum components for AML/CFT programs required by the Anti-Money Laundering Act of 2020 (AML Act) as well as technical changes to promote clarity and consistency across the rules for...

Apr 5, 2024 | datamatters.sidley.com | Joel D Feinberg |David E Teitelbaum |Stanley J. Boris

On March 28, 2024, the Financial Crimes Enforcement Network (FinCEN), in consultation with the U.S. banking agencies and the National Credit Union Administration, issued a request for information (RFI) regarding the customer identification program (CIP) requirement for depository institutions (referred to herein as banks) to collect tax identification numbers (TINs).1 Comments are due by May 28, 2024.

Apr 4, 2024 | lexology.com | Joel D Feinberg |David E Teitelbaum |Stanley J. Boris

On March 28, 2024, the Financial Crimes Enforcement Network (FinCEN), in consultation with the U.S. banking agencies and the National Credit Union Administration, issued a request for information (RFI) regarding the customer identification program (CIP) requirement for depository institutions (referred to herein as banks) to collect tax identification numbers (TINs).1 Comments are due by May 28, 2024.

Feb 14, 2024 | lexology.com | Paul Tyrrell |Jay G. Baris |Elizabeth Shea Fries |Stephen Cohen |Timothy J. Treanor |Stanley J. Boris | +1 more

On February 13, 2024, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) withdrew its 2015 notice of proposed rulemaking (NPRM) related to registered investment advisers (RIAs) and released a new notice of proposed rulemaking seeking to impose anti-money-laundering/counter-terrorist financing (AML/CTF) program requirements for the U.S. Securities and Exchange Commission (SEC) RIAs along with SEC exempt reporting advisers (ERAs).1 The addition of ERA as a covered investment...