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FinCEN Proposing a No-Action Letter Process

By Tom Ochsenschlager, J.D., CPA

On June 3, 2022, the Financial Crimes Enforcement Network (FinCEN) released an Advance Notice of Proposed Rulemaking stating that it would be developing a “No-Action Letter” process for financial institutions to utilize to ensure they were in compliance with the Bank Secrecy Act and rules, laws and regulations covering activities such as money laundering and financing terrorism. This only relates to the enforcement of financial crimes and is not directly relevant to taxation.

A no-action letter is provided by staff of a government agency that is requested by an entity subject to the regulation of that agency that concludes the agency will not take action against the entity if the entity complies with the terms of the no-action letter.

The FinCEN no-action letters will be applicable to the following institutions:

  • Casinos,
  • Depository institutions,
  • Insurance industry,
  • Money services businesses,
  • Mortgage companies/broker,
  • Precious metals/jewelry industry,
  • Securities and futures.

FinCEN is seeking written comments through Aug. 5, 2022.


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