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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

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

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

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

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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