Davis Polk Discusses New Permission for Banks to Collect Customer SSNs from Third Parties

In a significant step towards modernizing Bank Secrecy Act compliance, FinCEN and certain banking agencies are providing flexibility in “know your customer” requirements for banks.

The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), …

Arnold & Porter Discusses Final FinCEN Rules for Investment Advisers Under Bank Secrecy Act

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule to add “investment adviser” to the definition of “financial institution” under the regulations implementing the Bank Secrecy Act (BSA). The final rule defines the term “investment …