I usually write about mortgage or real estate professionals, but since I teach Anti-Money Laundering classes, I thought it would be helpful for all small businesses to know what’s coming. On September 18, 2023 the Financial Crimes Enforcement Network (FinCEN) published the final rules for the new Corporate Transparency Act (CTA). These rules become effective January 1, 2024 and in typical government practice, there is a Small Entity Compliance Guide. This new law is related …
FINRA Regulatory Notice 18-19 issued May 11, 2018 expands AML Program requirements to include additional risk-based procedures, or the “fifth pillar” required for AML programs under the new FinCEN CDD Ruling Since all AML programs are customized based upon the size and risk of a Mortgage Lender, Broker or Individual Licensee, the application of the “fifth” pillar must be factored into all programs beginning on May, 11, 2018. Therefore all AML programs must be modified …