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The High Points: SARs and the Three Tiered Framework for MRBs
Category: Anti-Money Laundering , Banking, Coronavirus (COVID-19)
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…
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Accuracy Counts: Filing Complete and Accurate SARs and Program Specific Red Flags Related to Covid-19 Criminal or Fraudulent Activity
Category: Anti-Money Laundering , Banking, Coronavirus (COVID-19)
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…
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Agent Fees and the Payment Protection Program
Category: Banking, Business, Class Action, Coronavirus (COVID-19), Legislative Updates
Last week, Arkansas saw its first class action where “agents” claimed entitlement to payment of fees under the Payment Protection Program (PPP).[1] This class action illustrates another area of confusion surrounding the administration of the CARES Acts (the “Act”). Congress created the PPP as part…
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Bankruptcy Courts are Easing Traditionally Rigid Lease Payment Requirements for Commercial Tenants In COVID-Related Filings
Category: Banking, Bankruptcy, Restructuring & Creditor-Debtor Rights, Business, Coronavirus (COVID-19), Litigation
Bankruptcy courts in multiple jurisdictions have granted tenant-friendly relief to companies that have filed for Chapter 11 bankruptcy in recent months. While the Bankruptcy Code typically requires timely performance of lease obligations under 11 U.S.C. § 365, bankruptcy courts have employed…
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The SBA Is Accepting New CARES Act Applications; Can Businesses Apply For More Than One Loan?
Category: Banking, Business, Coronavirus (COVID-19)
The President signed the Paycheck Protection Program and Health Care Enhancement Act into law on April 24, 2020, injecting an additional $484 billion in aid to supplement the SBA business loan programs created under the CARES Act. In particular, the new Act dedicated the following SBA funds: An…
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