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Broker-Dealer Financial Crimes

White & Case LLP

FinCEN Issues Final Sweeping AML Requirements for Registered Investment Advisers & ERAs

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On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more

K2 Integrity

Pending FinCEN Investment Adviser Rule: Industry Perspective On Next Steps You Should Be Taking

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On 22 August 2024, K2 Integrity hosted a webinar discussing considerations related to the pending anti-money laundering rule (AML) for investment advisers (IAs) from the Financial Crimes Enforcement Network (FinCEN). The...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Carlton Fields

Regulators Seek to Saddle Industry With New Obligations: Firms Bridle and Stir Up Opposition

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The Financial Crimes Enforcement Network (FinCEN), the Commodity Futures Trading Commission (CFTC), and the SEC have adopted or are proposing substantial increases in regulation of industry participants, primarily investment...more

Polsinelli

Blockchain+ Bi-Weekly - February 2024 #2

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The Blockchain Bi-Weekly presented by the Polsinelli Blockchain+ team is a rundown of some of the key stories in the Web3, blockchain and crypto ecosystems curated by our attorneys navigating the intersections of code, smart...more

Ballard Spahr LLP

FinCEN Proposes BSA Reporting Requirements for Residential Real Estate

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On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more

Paul Hastings LLP

FinCEN Proposes AML and SAR Filing Obligations for RIAs and ERAs

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On February 13, 2024, the United States Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would apply comprehensive anti-money laundering and countering the financing of terrorism...more

Troutman Pepper

FINRA Finds Potential Rule Violations in Crypto Asset Sweep

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In November 2022, the Financial Industry Regulatory Authority (FINRA) launched a targeted crypto asset sweep, reviewing more than 500 retail communications related to crypto assets from member firms....more

Goodwin

FINRA Publishes 2024 Annual Regulatory Oversight Report

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On January 9, 2024, FINRA published its 2024 Annual Regulatory Oversight Report (the “Report”). FINRA publishes the Report as a way to provide its broker-dealer members with insight into findings from FINRA’s Member...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules in Q1 2024

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Lowenstein Sandler LLP

Governor Signs New York LLC Transparency Act into Law

On Dec. 22, New York Governor Kathy Hochul signed the New York Limited Liability Company Transparency Act (“NY LLC Transparency Act”) into law. The NY LLC Transparency Act is modeled on the Corporate Transparency Act (“CTA”),...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Cozen O'Connor

Important Information Regarding Corporate Transparency Act Which May Require Action in 2024

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A new regulation under the federal Corporate Transparency Act (“CTA”) will require disclosure of information about all corporations, limited liability companies and limited partnerships (unless exempt) and personal...more

Faegre Drinker Biddle & Reath LLP

New Year’s Priorities: FINRA Releases its 2023 Report on its Examination and Risk Monitoring Program

Yes, (somehow) it is that time of year again. FINRA recently released its 2023 Report on its Examination and Risk Monitoring Program (the “Report”). As is typical (and this blog has well-covered), it contains a mix of old and...more

Troutman Pepper

FINRA Issues 2023 Examination and Risk Management Program Report: What It Says and How to Respond

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On January 10, FINRA published its “2023 Report on FINRA’s Examination and Risk Management Program” (Report) — FINRA’s third annual compendium of guidance, covering key topics and emerging risks for member firms to consider...more

BakerHostetler

FINRA Signals Expanded Enforcement Priorities in Annual Report

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The 2023 Report on FINRA’s Examination and Risk Monitoring Program was published on Jan. 10, 2023. In a statement accompanying the Report, Greg Ruppert, executive vice president of FINRA’s Member Supervision organization,...more

Mayer Brown Free Writings + Perspectives

FINRA Releases 2023 Report on Its Examination and Risk Monitoring Program

On January 10, 2023, the Financial Industry Regulatory Authority, Inc. (“FINRA”) released its 2023 Report on FINRA’s Examination and Risk Monitoring Program (the “Report), available at:  2023 Report on FINRA’s Examination and...more

McGlinchey Stafford

FinCEN Issues Final Rule Establishing Beneficial Ownership Information Requirements

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On September 29, 2022, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule that establishes a beneficial ownership information (BOI) reporting requirement that will require reporting...more

Winstead PC

Undue Influence, Detecting Elder Abuse, and the Duty to Report Financial Exploitation

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Author David F. Johnson recently presented his paper on “Undue Influence, Detecting Elder Abuse, and the Duty to Report Financial Exploitation” to the Austin Probate Bar Association in Austin, Texas, on May 20, 2022. This...more

The Volkov Law Group

FINRA Reminds Broker-Dealers on Importance of Compliance with New AML Rules

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The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements.  There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will...more

Katten Muchin Rosenman LLP

Bridging the Weeks - July 2019 #4

The Commodity Futures Trading Commission and the Securities and Exchange Commission brought separate enforcement actions against the portfolio manager of a hedge fund for mismarking valuations of interest rate swaps in order...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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Incoming Goldman CEO David Solomon has chosen his top deputies, settling on investment banking vets John Waldron (49) and Stephen Scherr (54) as his president/COO and CFO, respectively, and signaling the firm’s shift away...more

Perkins Coie

SEC and U.S. Attorney’s Office Bring Action Against Promoter of Bitcoin Store, Inc.

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On June 30, 2017, the SEC and the U.S. Attorney brought parallel civil and criminal fraud charges against Renwick Haddow, the owner of an unregistered broker-dealer entity named InCrowd Equity Inc., and two corporate entities...more

A&O Shearman

Financial Regulatory Developments Focus - September 2016

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In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

Stinson - Corporate & Securities Law Blog

FinCEN Proposes Amendments to Bank Secrecy Act to Cover Crowdfunding Portals

FinCEN, a bureau of the Department of the Treasury, has proposed amendments to the definitions of “broker or dealer in securities” and “broker-dealer” under the regulations implementing the Bank Secrecy Act. This rulemaking...more

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