Reporting Requirements under the Corporate Transparency Act may Effect More Entities than Anticipated
May 26, 2021
by Allison E. Raley
Congress recently passed the Corporate Transparency Act (CTA) requiring private companies to disclose their beneficial owners to the United States Department of the Treasury’s Financial Crime Enforcement Network (FinCEN). The CTA is designed to ban the anonymous shell companies criminals may use to…
The Benefit of Achieving Tier III Classification for Marijuana and Cannabis Related Businesses
January 5, 2021
by Allison E. Raley
In 2020 the legal segment of the marijuana industry exceeded $10 billion dollars in the United States with California alone generating $3.1 billion in sales in 2019, and Colorado in a close second at $1.6 billion. With the solidified foothold the industry has gained in the marketplace and the sheer…
The High Points: SARs and the Three Tiered Framework for MRBs
October 1, 2020
by Allison E. Raley
As green states continue to grow, intentional or unintentional exposure to Marijuana Related Business (“MRB”) customers for financial institutions and broker-dealers is an inevitability. Whether your business has decided to actively shoulder the risk of allowing MRB customers in pursuit of the…
Accuracy Counts: Filing Complete and Accurate SARs and Program Specific Red Flags Related to Covid-19 Criminal or Fraudulent Activity
On September 29, 2020, at the 19th Annual AML & Anti-Financial Crime Conference, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco reported over 91,000 suspicious activity reports (“SARs”) have been filed related to Covid-19 criminal and fraudulent activity. These 91,000…