The Financial Crimes Enforcement Network (FinCEN) has issued a final rule impacting U.S.-based aircraft lessors and operators. This new regulation specifically addresses reporting requirements related to suspicious activity reports (SARs). The finalized guidance clarifies that certain types of aircraft leasing arrangements, particularly those involving foreign ownership or transactions, are no longer considered ‘covered entities.’ Previously, these aircraft lessors were obligated to file SARs for specific transactions. FinCEN's action aims to reduce the administrative burden on these businesses while maintaining robust anti-money laundering efforts. The change takes effect November 20, 2023, providing clarity for industry participants.
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