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Tuesday, April 21, 2026

New FinCEN Director Addresses Key Topics in BSA/AML - JD Supra

The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director Gacki addressed the issues of beneficial ownership under the Corporate Transparency Act (“CTA”); the real estate industry; investment advisers; fentanyl trafficking; and whistleblowers under the Bank Secrecy Act (“BSA”).

The CTA

Director Gacki referenced various recent publications by FinCEN on the CTA, and stated that “we’ll be standing up a dedicated beneficial ownership information contact center. Based on the questions received through the Regulatory Helpline, we will issue additional FAQs on a rolling basis.” Further, Director Gacki stated that, “[t]o say there is a significant amount of work happening would be an understatement. But there is more work to be done.” This oblique statement does not indicate whether the CTA database in fact will be functional by its statutory effective date of January 1, 2024. As we have blogged, FinCEN has been criticized for being slow in rolling out regulations and information regarding the CTA.

Real Estate and Investment Advisers

Switching gears and referencing the White House’s 2021 U.S. Strategy on Countering Corruption, Director Gacki explained that FinCEN has been examining the money laundering risks and vulnerabilities with certain so-called “gatekeeper” industries such as real estate and investment advisers....



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