News & Analysis as of

Enforcement Actions SAR

Orrick, Herrington & Sutcliffe LLP

FinCEN data reveals Russian oligarchs’ financial activity

On December 22, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis on the financial activity of Russian oligarchs. ...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

Goodwin on

In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

UB Greensfelder LLP

FINRA AML Settlements Drive Home The Point: When It Comes To Supervision, Actions Speak Louder Than Words

UB Greensfelder LLP on

The longer I do this, the more apparent it becomes just how little anything changes. Sure, some things do change, a little. Rule numbers may get updated, as Rule 2310 becomes Rule 2111. Things that once may have been done...more

Ballard Spahr LLP

Investment Management Update - October 2015

Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

McGuireWoods LLP

FinCEN Announces Caesars Penalty After Multiyear Investigation

McGuireWoods LLP on

This week the Financial Crimes Enforcement Network (FinCEN) announced a Consent Agreement that imposed an $8 million civil penalty against Desert Palace, Inc. d/b/a Caesars Palace. Caesars first disclosed the investigation in...more

The Volkov Law Group

FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers

The Volkov Law Group on

FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...more

McGuireWoods LLP

Mind the Red Flags – FinCEN Issues Penalty for Failure to File SARs on Director’s Suspicious Activity

McGuireWoods LLP on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently penalized First National Community Bank (FNCB) $1.5 million for failing to file suspicious activity reports (SARs) despite the existence of...more

Burr & Forman

“No News Is Bad News” on BSA Compliance

Burr & Forman on

Addressing SIFMA’s Anti-Money Laundering (“AML”) conference Wednesday, SEC Enforcement Director Andrew Ceresney said that – when it comes to AML – the lack of red flags itself is a red flag....more

Dorsey & Whitney LLP

This Week In Securities Litigation

Dorsey & Whitney LLP on

The SEC settled another action this week based on admissions of fact and that the Federal securities laws were filed, this time involving Oppenheimer. The action was based on the fact that the firm permitted an off-shore and...more

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