27 March 2016
The purported “Final Rule” that FinCEN released on Friday, 25 March 2016, is not in fact “final” at all. It is subject to a preliminary injunction by a federal court in Washington D.C. that bars the rule from taking effect pending further inquiry by that court into the fairness, accuracy and legality of FinCEN’s process. The “Final Rule” is also subject, by its own terms, to a four-month waiting period between official publication and effective date. FBME has every right and intention to challenge the legality of the “Final Rule” so that the U.S. court can decide whether it should ever take effect.