IIUSA recently learned of a change at the head of the EB-5 Program within the United States Citizen and Immigration Services (USCIS) as Nicholas Colucci assumes the position of Acting EB-5 Program Chief previously held by Daniel Renaud.
Colucci has a long history of serving in government, most recently as Associate Director of the Analysis and Liaison Division at the Department of Treasury Financial Crimes Enforcement Network (FinCEN). In this role, Colucci was responsible for fusing Bank Secrecy Act data with all-source information to produce analytic products supporting the needs of domestic law enforcement at the Federal, State, and local levels, and the intelligence community. Prior to the Department of Treasury, Colucci served with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) as Deputy Assistant Director in the Office of Public and Government Affairs. Read his bio here.
This change is indicative of a larger transformation of the EB-5 Office with USCIS. On May 6, 2013 USCIS opened its new Washington, DC EB-5 Program Office, staffed by new GS-14 high-level economists and fraud detection and national security experts.
What is FinCEN?
FinCEN is a bureau of the U.S. Department of the Treasury. The Director of FinCEN is appointed by the Secretary of the Treasury and reports to the Treasury Under Secretary for Terrorism and Financial Intelligence. FinCEN’s mission is to safeguard the financial system from illicit use and combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities.
According to Department of Treasury website, “FinCEN’s mission is to safeguard the financial system from illicit use and combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities.”
FinCEN carries out its mission by receiving and maintaining financial transactions data; analyzing and disseminating that data for law enforcement purposes; and building global cooperation with counterpart organizations in other countries and with international bodies.
FinCEN exercises regulatory functions primarily under the Currency and Financial Transactions Reporting Act of 1970, as amended by Title III of the USA PATRIOT Act of 2001 and other legislation, which legislative framework is commonly referred to as the “Bank Secrecy Act” (BSA). The BSA is the nation’s first and most comprehensive Federal anti-money laundering and counter-terrorism financing (AML/CFT) statute. In brief, the BSA authorizes the Secretary of the Treasury to issue regulations requiring banks and other financial institutions to take a number of precautions against financial crime, including the establishment of AML programs and the filing of reports that have been determined to have a high degree of usefulness in criminal, tax, and regulatory investigations and proceedings, and certain intelligence and counter-terrorism matters. The Secretary of the Treasury has delegated to the Director of FinCEN the authority to implement, administer, and enforce compliance with the BSA and associated regulations.