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Treasury Issues Final Investment Advisers AML/CFT Program Rule

Treasury issued a final rule requiring certain investment advisers to establish an AML/CFT Program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Final Rule). The Final Rule applies to...more

SEC, FinCEN Propose CIP Rules for Investment Advisers

The Proposed Rule would require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish, document and maintain written customer identification programs (CIPs). The Proposed Rule comes...more

Congress Enacts Significant Changes to the U.S. Anti-Money Laundering Regime

The Anti-Money Laundering Act of 2020 (AML Act), enacted on January 1, 2021 as part of the National Defense Authorization Act for Fiscal Year of 2021 (NDAA), makes several significant changes to U.S. anti-money laundering...more

Two Non-U.S. Banks Agree to Pay Penalties Totaling $160 Million for Violations of U.S. Sanctions Laws Resulting from Omnibus...

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more

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