FinCEN provides further SAR Clarity

February 2021

On January 19, 2021, FinCEN issued Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations.  The answers to seven questions were provided by FinCEN in response to recent Bank Secrecy Act Advisory Group (BSAAG) recommendations,

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¿Estarán las Instituciones Financieras Preparadas para la Propuesta de Reglamentación del “Travel Rule”?

February 2021

El “Travel Rule” es una regla de la Ley de Secreto Bancario (“BSA”) regla [31 CFR 103.33(g)] y requiere que todas las instituciones financieras transmitan cierta información a la siguiente institución financiera, en ciertas transferencias de fondos que involucren a

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FinCEN provides a Section 314(b) welcomed clarification

January 2021

Section 314(b) of the USA PATRIOT Act (Sec 314) was drafted by Congress in 2001 to allow financial institutions to work with law enforcement agencies and with each other to support the common goal of deterring money laundering and terrorist

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Get Started with Reducing your 2020 Tax bill now

December 2020

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The Anti-Money Laundering Act of 2020 may be a Game-Changer for Compliance Professionals

December 2020

On December 2, 2020, the ‘‘William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021’’ was passed by the U.S. House of Representatives.  The Act includes DIVISION F (ANTI-MONEY LAUNDERING).  This Division is cited as the ‘‘Anti-Money Laundering

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IRS Agents Use Methods of Proof

December 2020

The IRS has tools inside of its Internal Revenue Manual (“IRM”) available to its agents for determining a Taxpayer’s taxable income as well as documenting its adjustments and corrections through what it calls “Methods of Proof”.  The IRM describes seven

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A Forensic Accountant digs beneath the surface and finds what is missing

December 2020

The decision to hire a Forensic Accountant can be a gamble. Not all possess critical characteristics such as being able to see beyond what is immediately in front of them utilizing a panoramic approach.  Traditionally, a CPA looks at historical

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Working together, Attorneys and Forensic Accountants Can Bring About Optimal Solutions

December 2020

There is a value added for a client when an Attorney is working in tandem with a forensic accountant. Litigation often involves overlapping complex accounting and legal issues. Working together, Attorneys and Forensic Accountants can bring about optimal solutions. Clients

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Compliance Shall Not be “Underfunded”

December 2020

Compliance Professionals continue protecting their Financial Institutions during these unprecedented times. They have become a source of regulatory information for Financial Institutions facing challenges that are changing from day to day.  As the Pandemic continues, Compliance Departments and Compliance Officers

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After Ten Years, FATCA is NOT GOING AWAY!

December 2020

FATCA was signed into law in March 2010 with the objective of combating international income tax reporting non-compliance by US citizens and U.S. taxpaying residents (US Taxpayers). It requires Foreign Financial Institutions (FFIs) to annually report the reportable balances and

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“Reasonable Cause” When Dealing with the IRS

December 2020

On November 5, 2020, the IRS removed the Delinquent Information Submission Procedure Program from its Offshore Compliance Options Menu.  Before the removal of this program, a US Taxpayer could file a “delinquent” international information tax return with what is known

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