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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

The United States Establishes the Foundation for a New Outbound Investment Regime

In brief. On August 9, 2023, President Biden signed a highly anticipated Executive Order (the “Outbound E.O.”) to establish a U.S. outbound investment regime. The U.S. Department of Treasury (“Treasury”) concurrently...more

FinCEN Corporate Transparency Notice of Proposed Rulemaking: Access to Beneficial Ownership Information and FinCEN Identifiers

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule (Proposed Rule) on December 15, 2022, implementing the requirements of Section 6403 of the Corporate Transparency Act (Act)...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

OFAC Issues Guidance Indicating Aggressive Interpretation of China Military Company Sanctions

On December 28, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) released guidance on the implementation of sanctions targeting securities of Communist Chinese military companies (“CCMCs”) imposed...more

SEC Rule Proposal: Good Faith Determinations of Fair Value Under the Investment Company Act

The U.S. Securities and Exchange Commission on April 21, 2020 proposed a long-anticipated framework for fair valuation of fund investments. Proposed Rule 2a-5 under the Investment Company Act of 1940 would establish...more

Newsflash: SEC Proposes Fund Valuation Rule

On April 21, 2020, the U.S. Securities and Exchange Commission proposed a long-anticipated framework for valuation of fund investments. Proposed Rule 2a-5 under the Investment Company Act of 1940 would establish requirements...more

SEC Takes Further Action to Assist Funds in Light of COVID-19 Coronavirus Pandemic: Provides Flexibility for Funds and Insurance...

On March 23, 2020, the Securities and Exchange Commission issued an order providing relief to registered open-end funds and insurance company separate accounts (separate accounts) registered as unit investment trusts. The...more

SEC Updates and Extends Its Targeted Actions to Assist Funds and Advisers in Light of COVID-19 Coronavirus Pandemic

On March 25, 2020, the Securities and Exchange Commission issued two orders updating and extending relief previously provided to registered funds and investment advisers whose operations may be affected by the COVID-19...more

SEC Adopts Amendments to Auditor Independence Rule to Address the “Loan Provision”

The U.S. Securities and Exchange Commission on June 18, 2019 adopted amendments to Rule 2-01(c)(1)(ii)(A) under Regulation S-X – the so-called “Loan Provision” (Final Rule). The Final Rule will become effective on October 3,...more

SEC Proposes Amendments to Auditor Independence Rule to Address the “Loan Provision”

The U.S. Securities and Exchange Commission (SEC) voted unanimously on May 2, 2018 to propose amendments to Rule 2-01(c)(1)(ii)(A) under Regulation S-X – the so-called “Loan Provision” (Proposal). Generally, the Loan...more

OFAC Issues Important Updates and Clarifications to Russia Sanctions

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury issued updated general licenses and related guidance in connection with sanctions imposed in April on certain Russian individuals and entities...more

FinCEN Issues FAQs for Customer Due Diligence Rule; Compliance Required in May

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) on April 3, 2018 issued Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions (FAQs). The FAQs address various...more

The Congressional Review Act: Striking a New Balance between Congressional Control and Regulatory Initiative – The Fate of the...

After more than two decades in obscurity, the Congressional Review Act (CRA) has now emerged as a major factor in the relationship between the U.S. Congress and the regulatory agencies....more

US Imposes Sanctions on Venezuelan Government Securities

The United States announced new sanctions against the Venezuelan Government on August 25, 2017 that target the government’s ability to access U.S. debt and equity markets. The measures are intended to pressure Venezuelan...more

SEC Staff Issues Guidance on Fund Fee Structure Disclosures

In a Guidance Update published on December 15, 2016, the staff of the U.S. Securities and Exchange Commission’s (SEC) Division of Investment Management (Staff) articulated its views as to certain disclosure issues and...more

U.S. Government Issues Guidance to Reassure U.S. Banks Involved in Foreign Correspondent Relationships

The U.S. Department of the Treasury, together with other U.S. government agencies responsible for enforcing anti-money laundering (AML) and economic sanctions regulations, released guidance on August 30, 2016 in the form of a...more

SEC Staff Issues No-Action Relief on Auditor Independence and the “Loan Provision”

The U.S. Securities and Exchange Commission’s Division of Investment Management (the “SEC Staff”) last night issued a no-action letter (the “Relief”) to Fidelity Management and Research Company that provides guidance to...more

SEC Staff Publishes its Views on Oversight of Certain Payments to Financial Intermediaries

The staff of the U.S. Securities and Exchange Commission (SEC) Division of Investment Management (Staff) published a Guidance Update on January 6, 2016 related to mutual fund distribution and sub-accounting fees. In the...more

U.S. Government Takes Steps to Further Ease Restrictions on Cuba

U.S. Commerce and Treasury Department measures intended to further ease existing export and sanctions restrictions regarding Cuba took effect on September 21, 2015. These amendments to the Cuban Assets Control Regulations...more

U.S. Proposes to Subject Non-U.S. SEC Registered Investment Advisers to Anti-Money Laundering Rules

The United States is proposing rules that, for the first time, would subject investment advisers registered or required to be registered (RIAs) with the U.S. Securities and Exchange Commission (SEC) under the Investment...more

FinCEN Proposes Anti-Money Laundering Regulation for Investment Advisers

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015,1 pertaining to all investment advisers registered or required to be registered...more

US and Cuba Seek to Normalize Relations; US to Ease Certain Restrictions

President Obama announced on December 17, 2014 that the United States and Cuba will open talks seeking to restore full diplomatic relations, and that the United States will be taking a number of steps to ease restrictions in...more

12/18/2014  /  Barack Obama , Cuba , Foreign Relations
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