CORPORATE TRANSPARENCY | US
The Corporate Transparency Act (CTA) requires certain US companies, absent a limited exemption, to report beneficial owner information (BOI) to FinCEN, effective January 1, 2024. Reports are required to submitted by December 31, 2024 for entities established before January 1, 2024; 90 days for those established in 2024; 30 days for those established in 2025.
OFAC SANCTIONS | US
OFAC encourages any individual or entity who may have violated US sanctions regulations to self-disclose apparent violations. Voluntary self-disclosures must include or to be submitted as a follow through within a reasonable period of time, which sufficiently provides a complete understanding of circumstances of the apparent violation/s.
OFAC SANCTIONS | US
OFAC requires covered persons or entities to fully comply with reporting obligations on blocked or unblocked property and rejected transactions. The initial reporting is required within 10 business days of the action or occurrence date with an Annual Report of Blocked Property (ARBP) to be filed by September 30.
AML AND SANCTIONS PROGRAMS
PART 504 CERTIFICATION | NEW YORK
All NYS DFS Covered Entities must establish and maintain transaction monitoring and watchlist filtering programs and are required to annually certify compliance by April 15 with Part 504.
CYBERSECURITY PROGRAM
PART 500 CERTIFICATION | NEW YORK
All NYS DFS Covered Entities must establish and maintain a cybersecurity program and, absent an exemption, are required to annually certify material compliance or an acknowledgement of noncompliance by April 15 with Part 500.
CYBERSECURITY INCIDENT
PART 500 | NEW YORK
All NYS DFS Covered Entities are required under Part 500 to report the occurrence of a cybersecurity event as soon as possible, but no later than 72 hours.
CYBERSECURITY INCIDENT | TEXAS
Texas Department of Banking (TX DOB) requires regulated entities, including MSBs, to report any significant cybersecurity or computer-security related incidents, as soon as possible, but no later than 15 days, and prior to consumer notification.
MONEY TRANSMITTER LICENSING | US
All US state-licensed money transmitters are required to complete the MSB Call Report, which includes national and state-level MSB financial and transactional data submitted on a quarterly and annual basis through NMLS.
MONEY SERVICES BUSINESSES | US
The Bank Secrecy Act (BSA) requires a MSB performing certain services to register with FinCEN. The owner or controlling person of the MSB must initially register with FinCEN within 180 days after the MSB establishment date.
FOREIGN BANK & FINANCIAL ACCOUNTS | US
The BSA requires any US person who have financial interest in or signature authority over foreign accounts exceeding an aggregate value of $10,000 to annually file a Report of Foreign Bank and Financial Accounts (FBAR) on or before April 15 of the following year, absent an exemption.
CALIFORNIA FINANCING LAW | CALIFORNIA
The California Financing Law (CFL) requires all licensees under its regulation to file an annual report (CFL Annual Report) with the California Department of Financial Protection and Innovation (DFPI) on or before March 15 of the following year, even if no business was conducted.
MONEY SERVICES BUSINESSES | CANADA
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) requires reporting entity sectors, including MSBs, to comply with electronic funds transfer (EFT) reporting requirements. The MSB must submit an EFTR within five (5) business days after a transfer is initiated or received.
RISK | STRATEGY | CYBER COMPLIANCE MANAGEMENT
