Corporate Transparency Act: Considerations for Special Purpose Entities in Commercial Real Estate Transactions

Reported by Cameron Weil and Dustin W. Lauermann Special Purpose Entities in Commercial Real Estate Transactions Corporate structures in commercial real estate transactions can often be very complex and involve layers of entities. Special purpose entities that are bankruptcy remote (“SPEs”) are frequently used in commercial real estate loans to limit certain risks associated with […]

FinCEN issues analysis of increasing elder financial exploitation

Reported by Kristen E. Larson, Beth Moskow-Schnoll & Peter D. Hardy The Financial Crimes Enforcement Network (“FinCEN”) recently issued a Financial Trend Analysis (“Analysis”) focusing on patterns and trends identified in Bank Secrecy Act (“BSA”) data linked to Elder Financial Exploitation (“EFE”) involving scams or theft perpetrated against older adults. The Analysis is a follow up to FinCEN’s June 2022 EFE […]

The Price Cap on Russian Oil – Part 2: Updated OFAC Guidance

Reported by Richard J. Gibbon Of Squire Patton Boggs (US) LLP  –  Global Investigations And Compliance Review Updated OFAC Guidance on Implementation of the Price Cap Policy On December 20, 2023, OFAC updated its Guidance on the implementation of the price cap policy that was first issued on February 3, 2023.[2] In addition to clarifying details of the price cap policy, […]

The Updated FAQs On The Corporate Transparency Act

Reported by Matthew Erskine FinCEN has recently refined the Corporate Transparency Act FAQs, offering much-needed clarity and direction for businesses grappling with the intricacies of the CTA. These revisions play a crucial role in delineating the compliance obligations of both domestic and foreign reporting entities and their beneficial owners, aiming to bolster efforts against financial […]

FinCEN: Webinar on Beneficial Ownership Information Reporting Requirements

Reported by FinCEN The Corporate Transparency Act requires many companies doing business in the United States to report information to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) about who ultimately owns or controls them. Watch FinCEN representative for a virtual information session on beneficial ownership information reporting requirements and how to […]

Elder Fraud, in Focus

Elder fraud reports to FBI’s Internet Crime Complaint Center rose by 14% in 2023  Reported by The FBI’s Internet Crime Complaint Center (or IC3)  Elder fraud complaints to the FBI’s Internet Crime Complaint Center (or IC3) increased by 14% in 2023, and associated losses increased by about 11%, according to IC3’s 2023 Elder Fraud Report, released April 30. […]

SARs and fraud in 2024: Expect more — lots more

Reported by Tad Simons  Technology Journalist/Thomson Reuters Institute Fraud is on the rise almost everywhere, and there is no indication of a slowdown anytime soon, according to the statistics behind SARs filings The number of suspicious activity reports (SARs) — the documents that financial institutions must file with the federal government’s Financial Crimes Enforcement Network (FinCEN) […]

User Verification In Crypto: A Path Toward Or Away From Security?

Reported by David Balaban In March 2024, European Parliament committees approved a ban on anonymous digital asset transfers. If the EU Council and Parliament adopt these laws, they will take effect in three years. Some cybersecurity and cryptocurrency experts believe that mandatory user verification (KYC) could compromise personal data security. The Security Risks Introduced by KYC […]

This Bill Would Give the Treasury Nearly Unlimited Power To Destroy Nonprofits

Reported by MATTHEW PETTI A bipartisan bill would give the secretary of the treasury unilateral power to classify any charity as a terrorist-supporting organization, automatically stripping away its nonprofit status. The bill, H.R. 6408, already passed the House of Representatives in November, and a companion bill, S. 4136, was introduced to the Senate by Sens. John Cornyn (R–Texas) and […]