BSA/AML

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FinCEN’s NPRM Signals an Expanded Use of Section 311

The Financial Crimes Enforcement Network (FinCEN) recently issued a notice of proposed rulemaking (NPRM), pursuant to section 311 of the USA PATRIOT Act, finding that a class of transactions involving 10 Mexican gambling establishments are of “primary money laundering concern.” According to the press release announcing the NPRM, FinCEN has assessed that the gambling establishments have “directly and indirectly” facilitated money laundering benefiting a Mexico-based …

FinCEN Clarifies Certain Ambiguities in SARs Requirements

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued answers to FAQs to clarify certain requirements related to suspicious activity reports (SARs). The FAQs were jointly issued with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the Comptroller of the Currency. The FAQs do not establish …