OFAC RPPR Interim Final Rule
On 05/08/2024, OFAC amended and issued an interim final rule on the Reporting, Procedures and Penalties Regulations (RPPR) which sets forth standard reporting and recordkeeping requirements and license application and other procedures relevant to the economic sanctions programs administered by OFAC. The OFAC RPPR interim final rule requires electronic filing of certain submissions to OFAC […]
Trusts and the CTA
On April 18, 2024, FinCEN updated FAQs that address Trusts and the CTA (Corporate Transparency Act). Trusts are vehicles that can assist in the preservation of wealth and property for future generations, protect assets, or carry out a charitable purpose. A trust is an entity created and governed under the state law in which it […]
HOAs are Reporting Companies under the CTA
On 4/18/24, FinCEN updated its Beneficial Ownership Reporting FAQs and included for the first time information regarding HOAs (Home Owners Associations). FinCEN confirms in this update that HOAs are reporting companies under the Corporate Transparency Act (CTA) and are subject to BOI (Beneficial Ownership Information) reporting requirements if they are entities created by filing of […]
Access to BOI: FinCEN Phased Approach
On 4/18/24, FinCEN updated its FAQ Section and added a new section titled “Access to BOI Information”. This new section addresses the phased approach from FinCEN to providing access to BOI – beneficial ownership information – as FinCEN is not currently accepting requests for access to BOI. FinCEN states that it will provide further guidance […]
Dirty Dozen 2024
On 4/11/24, the IRS concluded the release of the Dirty Dozen 2024. The Dirty Dozen is an annual taxpayer awareness campaign which began in 2002 listing twelve scams and schemes that place taxpayers, businesses, and the tax professional community at risk of losing money, personal information, data and more. The Dirty Dozen 2024 is an […]
Tax Strategies and Schemes to Avoid Taxes at IRS Forefront
On 4/11/24, the IRS wrapped up its 2024 Dirty Dozen List with a “warning to taxpayers regarding promoters selling bogus tax strategies and fraudulent offshore schemes designed to reduce or avoid taxes altogether”. Tax strategies and schemes to avoid taxes remain a high priority for the IRS. “Taxpayers should be wary of anything that seeks […]
U.S. Passport Card Fraud FinCEN Notice
On 4/15/24, FinCEN in conjunction with the U.S Department of State’s Diplomatic Security Service (DSS), issued warning regarding U.S. Passport Card Fraud via Notice to financial institutions urging them to be vigilant in identifying and reporting suspicious activity related to the use of U.S. Passport Card Fraud for identity theft and fraud schemes. The purpose […]
Director Gacki from FinCEN Encourages Transparency in the U.S. Financial System
During the FIBA’s (Financial and International Business Association’s) annual anti-money laundering conference held from March 18, 2024, to March 21, 2024 in Miami, Florida, Director Gacki from FinCEN discussed regulatory expectations and best practices to prevent financial crimes in a fireside chat. Enhancing transparency in the U.S. financial system continues to be a top priority […]
Passport Revocation or Denial continues
On 1/1/24, the IRS updated its Passport Revocation or Denial Page in cases of certain unpaid taxes. Section 7345 of the Internal Revenue Code requires the U.S. Department of the Treasury to notify the U.S. Department of State if a certification is made that an individual has a “seriously delinquent tax debt.” The Internal Revenue […]
Fraud is the Number One Crime in Money Laundering
On February 2024, the U.S. Treasury released the 2024 National Money Laundering Risk Assessment (NMLRA) which examines the current money laundering environment and identifies the ways in which criminals and other actors seek to launder funds. The Assessment aims to: inform the understanding of illicit finance risk by governmental and private sector actors, strengthen risk […]
FATF Key Actions February 2024
On 2/23/24, the Financial Action Task Force (FATF), an independent inter-governmental entity that develops policies for protection of our global financial system from money laundering, terrorist financing and financing of weapons of mass destruction and considered to be the global money laundering and terrorist financing “watchdog”, concluded its fifth Plenary under the Singaporean presidency. The […]
BOI Access & Safeguards
On 2/20/23, FinCEN published the Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements. The (six-pages and four sections) BOI Access & Safeguards Guide provides an overview of the Beneficial Ownership Information Access and Safeguards Rule (Access Rule) requirements for small entities that obtain BOI from FinCEN and only pertains to authorized […]
