ARTICLE · 04 SEPTEMBER 2014

FinCEN's Busy August Yields Noteworthy Anti-Money Laundering Developments

Holland & Knight

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August was a busy month for the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN).

United StatesFinance and Banking

Andres Fernandez

Gabriel Caballero Jr.

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Andres Fernandez is a Partner and Gabriel Caballero is Senior Counsel in Holland & Knight's Miami office.

HIGHLIGHTS:

Financial institutions should be aware of several anti-money laundering initiatives issued by the U.S. Treasury's Financial Crimes Enforcement Network, FinCEN, during an especially busy month of August.
Among other topics, the recent FinCEN regulations, advisories, guidance and penalties involve CDD requirements for financial institutions, violations of the Bank Secrecy Act, misuse of armored cars and the application of MSB regulations to independent sales organizations and payment processors.

August was a busy month for the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). Among other initiatives, FinCEN issued its long-awaited proposed regulations on customer due diligence (CDD) requirements for financial institutions, multiple advisories/guidance and civil money penalties for violations of the Bank

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