Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) announced a proposed rule (“Proposed Rule”) that would require certain depository institutions and money services businesses (“MSBs”) to affirmatively provide records to FinCEN of certain cross-border electronic transmittals of funds (“CBETF”). FinCEN proposes to define a CBETF as “a transmittal of funds where either the transmittal order or the device is: (i) communicated through electronic means; and (ii) sent or received by either a first-in or a last-out financial institution.” The term “first-in financial institution” refers to any bank or MSB that receives a transmittal order or the device of a transmittal order from a foreign financial institution.
Should you wish to receive further information concerning matters discussed in this publication, please contact:
Clemente L. Vazquez-Bello
305.376.6082 ▪ [email protected]
Andres A. Fernandez
305.376.6097 ▪ [email protected]
Marina Olman
305.376.6069 ▪ [email protected]
