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Treasury Revisits Past Rulemaking to Bring Investment Advisers Under AML Oversight

In connection with the Biden Administration’s ongoing crackdown on corruption, tax havens, and illicit financing, on December 11, Treasury released a Fact Sheet on its “efforts to address the illicit finance and national...more

Warning: SEC Exams and Enforcement Targeting Broker-Dealer AML Compliance

For years, the SEC has focused on broker-dealers complying with all applicable AML and financial sanctions laws and regulations, including the BSA and its implementing regulations. For example, in 2021, the Division issued a...more

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more

Treasury Plans Significant Actions to Curb Illicit Digital Asset Financing

As part of a coordinated effort with the U.S. Secretary of State, Attorney General, Secretary of Commerce, Secretary of Homeland Security, Director of the Office of Management and Budget, Director of National Intelligence,...more

FinCEN Requires Wide Array of Companies To Report Beneficial Ownership Information To Strengthen Transparency of US Financial...

On September 29, 2022, FinCEN issued a final rule requiring most corporations, limited liability companies and other entities created in or registered to do business in the United States to report information regarding their...more

Applying the Bank Secrecy Act, FinCEN Regulations, and Sanctions to the Nascent NFT Market

Non-fungible tokens (NFTs) often involve two areas with known money laundering and terrorist financing risks: cryptocurrencies and high-value assets, like art. As detailed below, the U.S. Treasury Department’s Financial...more

SEC Sanctions Broker-Dealer for Paper-Only AML Program

On June 1, 2016, the Securities and Exchange Commission (SEC) for the first time ever charged a broker-dealer in a stand-alone action for failing to file suspicious activity reports (SARs) as required by the federal...more

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