On Oct. 23, 2023, FinCEN published an NPRM that identifies international CVC mixing as “a class of transactions of primary money laundering concern,” and finds that imposing additional recordkeeping and reporting requirements on “covered financial institutions” would help mitigate the risks such transactions pose. The NPRM’s proposed reporting requirements would be in addition to any obligation to file Suspicious Activity Reports (SARs). FinCEN has invited comments on all aspects of the NPRM, including several questions posed. Comments will be accepted through Jan. 22, 2024.
FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing
