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Recordkeeping Requirements Risk Assessment

Pillsbury Winthrop Shaw Pittman LLP

The EU’s AI Act: A Review of the World’s First Comprehensive Law on Artificial Intelligence and What This Means for EU and Non-EU...

The agreed text of the AI Act was published on July 12, 2024, essentially starting the clock on the legal deadlines contained in it. Its obligations will apply in tiered phases, with the first key obligations being enforced...more

WilmerHale

What Are High-Risk AI Systems Within the Meaning of the EU’s AI Act, and What Requirements Apply to Them?

WilmerHale on

In this blog post, we will focus on the identification of “high-risk AI systems” under the Artificial Intelligence Act (“AI Act”) and the requirements applying to such systems. As explained in our previous blog posts, the AI...more

Mayer Brown Free Writings + Perspectives

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more

Seward & Kissel LLP

FinCEN Proposes AML Requirements for Certain Investment Advisers

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On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

ArentFox Schiff on

On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Anticorruption Red Flags (Part I)

Foley & Lardner LLP on

We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more

Morrison & Foerster LLP

FinCEN: Eyes on Investment Advisers

In July 2020, a sensitive Federal Bureau of Investigation (FBI) document was leaked to the public. The document outlined the FBI’s suspicions that the private investment funds industry was providing choice money laundering...more

StoneTurn

Risk Awareness and Mitigation in Disaster Recovery: After a Catastrophe

StoneTurn on

Natural disasters, while undoubtedly disruptive and damaging, can serve as powerful catalysts for organizational transformation if approached with foresight and strategic intent. As we’ve explored, successful post-disaster...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Proposes New Rule to Expand Anti-Money Laundering Requirements for Investment Advisers

Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

Walkers

Updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the...

Walkers on

Following industry consultation, on 30 August 2023 the Cayman Islands Monetary Authority ("CIMA") issued updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation...more

Wiley Rein LLP

California Eyes New Privacy, Cyber, and AI Obligations

Wiley Rein LLP on

California continues to forge ahead on potential new privacy, cybersecurity, and artificial intelligence (AI) obligations, including through its California Consumer Privacy Act (CCPA) rulemaking process and by launching a new...more

Walkers

Director exemptions: changes to AML obligations

Walkers on

Introduction - Further to a recent update, in which the Government, in consultation with the Jersey Financial Services Commission ("JFSC"), announced its intention to make legislative changes to the anti-money laundering,...more

Dechert LLP

SEC Proposes New Cybersecurity Risk Management Rule for Various Market Entities

Dechert LLP on

At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted three to two to propose a new rule, form and amendments (together, “Proposed Rule”) and published an accompanying release (“Release”)...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2023 - Hot (or at least warm) Off the Press: Updates & Revisions to the ITAR

The Directorate of Defense Trade Controls (DDTC) is continuing its project to revise and update the International Traffic in Arms Regulations (ITAR). Some of the changes are editorial and some are substantive. If you are...more

Torres Trade Law, PLLC

DDTC Updates Compliance Program Guidelines and Guidance for U.S.

Compliance Program Guidelines - On December 5, 2022, the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines (“the Guidelines”) intended to provide an overview...more

Guidepost Solutions LLC

Mergers + Acquisitions: 5 Tips For Navigating FCPA Risks

Among the risks inherent in a merger or an acquisition, few bring the financial and reputational consequences of the U.S. Foreign Corrupt Practices Act (“FCPA”). Background - The FCPA prohibits the offer, promise,...more

Sheppard Mullin Richter & Hampton LLP

Are You Ready for 2023? Here’s a Quick Checklist to Reduce Legal Risks in the New Year

The New Year energizes us to plan for success in the coming months. To increase the odds of meeting your business goals, we suggest taking a quick inventory of legal risks and brainstorming corrective actions for 2023...more

Foodman CPAs & Advisors

U.S. Department Of Labor Has “Serious Concerns” Over 401(K) Plan’s Investments In Cryptocurrencies

The U.S. Department of Labor cautions plan fiduciaries to exercise extreme care before they consider adding a cryptocurrency option to a 401(k) plan’s investment menu for plan participants....more

Jackson Lewis P.C.

SEC to Advisors and Funds – Adopt and Implement Cybersecurity Policies and Procedures

Jackson Lewis P.C. on

On February 9, the Securities and Exchange Commission (“SEC”) voted to propose rule 206(4)-9 under the Advisers Act and 38a-2 under the Investment Company Act (collectively, “Proposed Rule”). In general, the Proposed Rule...more

Cozen O'Connor

In The Absence Of Any Grave Danger, OSHA Still Issues A COVID-19 Emergency Temporary Standard But Limits Its Coverage To...

Cozen O'Connor on

On May 26, 2021, we told our readers that we thought that although an “emergency” no longer existed about OSHA’s need to regulate employers’ handling of the COVID-19 virus. OSHA would nonetheless still issue an emergency...more

Goodwin

SEC Adopts New Regulatory Framework For Registered Fund Derivative Investments

Goodwin on

On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more

Husch Blackwell LLP

Detailed Virginia COVID Regulation Takes Effect Today For Virginia employers

Husch Blackwell LLP on

Today, Virginia’s new and detailed COVID-19 regulation takes effect. The rule, an “emergency temporary standard” (ETS), was adopted July 15th by the Virginia Department of Labor and Industry (DOLI). Unlike general guidance...more

Dechert LLP

SEC Updates Rule 17H Risk Assessment Thresholds for Certain Broker Dealers

Dechert LLP on

The Securities and Exchange Commission issued an order (Order)1 on June 29, 2020, under Section 17(h)(4) of the Securities Exchange Act of 1934, raising the thresholds for compliance with the recordkeeping and reporting...more

Fisher Phillips

OSHA Releases Return-To-Work Guidance Addressing Assessments And Records

Fisher Phillips on

The Occupational Safety and Health Administration (OSHA) released a Guidance on Returning to Work document that describes strategies and recommends steps employers should take during all phases of reopening. Most of OSHA’s...more

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