Wynn Segall

May 23, 2024 | mondaq.com | Ryan Fayhee |Nnedinma Ifudu Nweke |Jason Prince |Wynn Segall

On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to blocked property and rejected transactions. Subject to any changes OFAC may make following a 30-day comment period, the proposed changes will become effective on August 8, 2024.

Feb 14, 2024 | lexology.com | Peter Altman |Michael Asaro |Brian Daly |Jason Daniel |Katherine Goldstein |Alexis Guinan | +11 more

Key PointsOn February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact sheet, RIAs and ERAs would be required to implement risk-based AML/CFT programs, file SARs with FinCEN, fulfill certain recordkeeping requirements and fulfill other obligations currently applicable to financial institutions subject to the BSA and FinCEN’s implementing regulations.