FINCEN Requires Financial Institutions to Obtain Beneficial Ownership Information
FinCEN also amended anti-money laundering rules.
FinCEN’s Final Rules, which fortuitously materialized on the heels of the so-called Panama Paper Disclosures, charged beneficial ownership disclosure obligations on certain legal entities that desired to gain access to the U.S. financial system. The Final Rules were part of a series of steps the Obama administration took to further combat money laundering, corruption, and tax evasion. This white paper reviews the beneficial ownership rule and changes to AML program rules and discusses observations to how the Final Rules impacted financial institutions.
Partner in the Washington D.C. office of Morgan, Lewis & Bockius LLP
Practice emphasizes all aspects of broker-dealers and securities intermediaries regulatory and compliance obligations, including antimoney laundering requirements, trading activities, financial responsibility and recordkeeping, margin and other requirements
Conducts regular seminars and workshops on numerous issues related to broker-dealer and securities intermediary compliance with federal and state law requirements, and self-regulatory organization rules
Author of several publications related to the areas of broker-dealer and securities intermediary regulation, including antimoney laundering requirements, trading activities, financial responsibility and recordkeeping, margin and other requirements
J.D. degree, American University, Washington College of Law; B.A. degree, University of California, Los Angeles