Are you in or out for beneficial ownership?
11/05/2017
Are there some exemptions for FinCEN’s beneficial ownership?
Peter Djinis is the founder of the firm, Law Offices of Peter Djinis, which specializes in civil and regulatory matters involving federal anti-money laundering and Bank Secrecy Act laws. The firm provides advice on the development of compliance and risk management standards for financial institutions, primarily relating to anti-money laundering and terrorist financing matters and the requirements of the Treasury Department's Office of Foreign Assets Control. With the passage of the USA PATRIOT Act, the universe of financial institutions subject to these controls includes banks and other depository institutions, securities broker-dealers, mutual funds and other investment companies, casinos, money services businesses, life insurance firms and many other businesses that offer financial services to the public. The firm provides independent assessments of these institutions' programs as well as assistance with internal investigations. Previously, Mr. Djinis served as Executive Assistant Director for Regulatory Policy for the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN), for which he was responsible for establishing regulatory policy and overseeing all aspects of Bank Secrecy Act (BSA) compliance by U.S. bank and non-bank financial institutions.
Over the past 16 years, Mr. Djinis has played a central role in the development of anti-money laundering legal requirements and controls, both within the U.S. and abroad. He often speaks on money laundering and Bank Secrecy Act compliance matters and has frequently appeared in the national media and testified before Congress on these issues. Before joining Treasury, he was a senior federal prosecutor with the Criminal Division of the U.S. Justice Department, where he successfully prosecuted several large drug trafficking and money laundering organizations.
Mr. Djinis can be reached at djinis@djinislaw.com.
11/05/2017
Are there some exemptions for FinCEN’s beneficial ownership?
10/07/2013
When an Affidavit of Small Estate is presented by a single Affiant to close a deposit account owned solely by the deceased, and there are multiple heirs listed, is the financial institution required to pay the funds to each named heir, or to the affiant to distribute to the heirs?
08/16/2004
When a deposit account customer of a bank purchases a cashier's checkfor $4,000 in cash, the bank obviously is required to record and retaincertain information. Assuming that at the time the original depositaccount was opened the customer's identity was verified and the customeris well-known to the bank employee conducting the transaction, whatneeds to be done to "verify" the customer?
02/17/2003
Does a SAR need to be filed every time a financial institution has a hit on the OFAC List? If so, what should be listed as the type of suspicious activity?