by Satish M. Kini, David G. Sewell, and Justin G. Maffett
On Monday, June 29, the Financial Crimes Enforcement Network (“FinCEN”) issued guidance (PDF: 289 KB) to financial institutions, addressing Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) obligations and expectations that apply when providing services to hemp-related businesses. Although last Monday’s guidance generally supplements and amplifies the December 3, 2019 interagency statement (PDF: 75.9 PDF) (which we described in a Client Update published late last year), we wanted to share the following notes and highlights: