An update on US transparency initiatives. 20 October 2022
The webinar will cover three topics: (1) the final beneficial ownership information (BOI) reporting regulations under the Corporate Transparency Act; (2) the Enabler's Act, and (3) US sanction developments in the private client space.
Corporate Transparency Act. As you may be aware, the BOI regulations currently are in the final stages of review at the Office of Information and Regulatory Affairs of the Office of Management and Budget. They were received by OIRA on August 30, which has 90 days in which to review the regulation package. It has been reported that over 400 comments were received in response to the proposed BOI regulations. It will be interesting to see how FinCEN balances the need for information against the reporting burden on in-scope entities.
The Enabler's Act. We will provide an update as to the progress of this Act in Congress. Under this Act, service providers, to include attorneys and accountants providing certain types of work, as well as persons performing financial advice, forming entities, rendering investment advice and servicing trusts would be required to conduct anti-money laundering (AML) due diligence.
Sanctions Update. We will provide a brief update on US sanction developments in the private wealth space.
Alan Winston Granwell, Of Counsel, Holland & Knight LLP, Washington, DC
Severiano E. Ortiz, Partner, Kozusko Harris Duncan, Washington, DC
Megan R. Worrell, Managing Director, J.P. Morgan Private Bank, New York, NY
Bruce Zagaris, Partner, Berliner Corcoran & Rowe LLP, Washington, DC