New Hemp-related Business Guidance
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Currency Transaction Reports: Fin-2020-R001
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Beneficial Ownership and Lending: Have we considered all possibilities?
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FinCEN issues Exceptive Relief for Certificate of Deposit and Loan Renewals
Many TCA clients have expressed concerns regarding FinCEN’s position that automatic renewals of certificates of deposits and loans are considered new accounts which require that a financial institution obtain a Certification of Beneficial Ownership for legal entity customers. Since FinCEN published the Frequently Asked Questions just one month prior to the mandatory compliance date, our …
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CDD and Auto-Renewing Products: Are you BSA Compliant
In eight days, the new 5th pillar – that includes Beneficial Ownership – takes effect. Starting May 11, 2018, Customer Due Diligence (CDD) will be added to the other four Bank Secrecy Act pillars. Right now, one of the most frequently discussed questions continues to be CD and loan renewals. TCA’s BSA Action Team (BAT) …
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Stunning Reversal by DOJ on Marijuana Enforcement
On January 4, 2018, Attorney General Jeff Sessions issued a Memorandum which reverses the Department of Justice’s (DOJ’s) stance on enforcement of the Controlled Substances Act as it relates to medical and recreational marijuana that is legal at the state level. How this will impact federal prosecution of the marijuana industry is uncertain, but the …
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