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Financial Industry Regulatory Authority (FINRA) Customer Due Diligence (CDD)

Parker Poe Adams & Bernstein LLP

Practical Tips for Broker-Dealers After SEC Flags Compliance Issue

Last month, the U.S. Securities and Exchange Commission (SEC) took a refreshed look at how broker-dealers are complying with anti-money laundering rules. What auditors discerned — as detailed in their July 31 risk alert — is...more

BCLP

New Federal Anti-Crime Rule Requires Millions of Businesses to Report True Ownership

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With limited amendments to its proposed rule, the Financial Crimes Enforcement Network (“FinCEN”), a division of the U.S. Department of the Treasury, recently promulgated its final rule (the “Reporting Rule”) implementing the...more

Dorsey & Whitney LLP

SEC Exam Priorities For RIAs and ICs

Dorsey & Whitney LLP on

The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more

A&O Shearman

FINRA Issues 2019 Annual Risk Monitoring and Examination Priorities Letter, Highlighting Potential Areas Of Enforcement Risk

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On January 22, 2019, the Financial Industry Regulatory Authority (“FINRA”) issued its annual letter describing its current risk monitoring and examination priorities. See FINRA, Risk Monitoring and Examination Priorities...more

Orrick, Herrington & Sutcliffe LLP

SEC and FINRA's Annual Rites – Announcing Their Examination Priorities

On January 22, 2019, FINRA published its 2019 Risk Monitoring and Examination Priorities Letter. Released several weeks later than usual, FINRA’s letter follows the December 10, 2018 publication of the 2019 Examination...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Katten Muchin Rosenman LLP

FINRA Publishes Its Annual Report on Examination Findings

On December 7, FINRA published its Report on 2018 Examination Findings1 (the "Report"). This is the second year that FINRA issued a summary of its observations from recent examinations. This Report, read in conjunction with...more

Saul Ewing LLP

What do FINRA’s New Anti-Money Laundering Program Requirements Mean for Borrowers?

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As of May 11, 2018 all member firms of the Financial Industry Regulatory Authority, Inc. (FINRA) were required to be in compliance with the provisions of the Customer Due Diligence Requirements for Financial Institutions (CDD...more

BCLP

Recent Developments Confirm AML is a Regulatory "Hot Button"

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The SEC continues to reiterate the role of broker-dealers as “gatekeepers to the securities markets” by focusing on firms’ anti-money laundering (“AML”) obligation. The import that the SEC, as well as FINRA, places on firms’...more

A&O Shearman

FinCEN’s Customer Due Diligence Rule Becomes Effective; FinCEN and FINRA Guidance Provides Interpretive Color for Firms Working to...

A&O Shearman on

May 11, 2018 marked the compliance date for the Customer Due Diligence Requirements for Financial Institutions rule issued by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) on May 11, 2016 (the...more

A&O Shearman

FINRA Updates AML Rules to Conform to Upcoming Customer Due Diligence Requirements

A&O Shearman on

The Financial Industry Regulatory Authority published amendments to FINRA Rule 3310, the anti-money laundering compliance program rule. The FINRA amendments seek to harmonize Rule 3310 with the Customer Due Diligence...more

Kramer Levin Naftalis & Frankel LLP

SEC, FINRA Target ICOs, Cybersecurity, Secondary Market Trading in 2018 Examination Priorities

Both the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) recently released their respective 2018 examination priorities, providing a glimpse into their plans for the year to...more

Eversheds Sutherland (US) LLP

Highlights from the SIFMA AML and Financial Crimes Conference

On February 12-13, 2018, members of the securities industry, regulators and financial crime experts met in New York City at the Securities Industry and Financial Markets Association (SIFMA) Anti-Money Laundering (AML) and...more

Kelley Drye & Warren LLP

FinCEN AND FINRA News for 2018

FinCEN Exchange to encourage information sharing In December 2017, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced the creation of a platform to facilitate information sharing on a voluntary...more

Manatt, Phelps & Phillips, LLP

AML News: FINRA Guidance

In the latest anti-money laundering news, the Financial Industry Regulatory Authority published guidance on AML obligations of firms subject to FINRA supervision. What happened - FINRA’s guidance supplements the...more

BCLP

FINRA Reg Notice 17-40: Is Your AML Program Ready For FinCEN’s CDD Rule?

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On November 21, 2017, FINRA issued Regulatory Notice 17-40 to provide member firms guidance regarding their obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program) in light of the Financial Crimes...more

Ballard Spahr LLP

Investment Management Update

Ballard Spahr LLP on

Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

Goodwin

Financial Services Weekly News - July 2016 #4

Goodwin on

Editor's Note - What Exactly Is Bitcoin? In a case featuring a sting operation beginning with meetings in a coffee shop, ice cream store and hotel lobby and ending with the sale of bitcoins to an undercover Miami Beach...more

Ballard Spahr LLP

Recent Investment Management Developments - May 2016

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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. ...more

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