SEC Activity with Fixed Income and Credit Funds
Podcast - Developments in FDA & DOJ Regulation and Enforcement of Manufacturer Communications
Foreign device manufacturers should anticipate greater chance of FDA inspection under new FDA leadership
The Financial Action Task Force ("FATF"), the global money laundering and terrorist financing (“ML/TF”) watchdog, recently issued updated guidance related to compliance risks resulting from activities involving Virtual Assets...more
Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more
The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to...more
The Financial Crimes Enforcement Network (FinCEN) and federal banking regulators recently issued a Joint Statement intended to clarify the due diligence obligations of banks under the Bank Secrecy Act (BSA) regarding...more
Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more
Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more
AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more
El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas. Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more
A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations. A Financial Institution’s OFAC compliance program is required to...more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
Established in 2003, the Basel Institute is a not-for-profit Swiss foundation dedicated to working with public and private partners around the world to prevent and combat corruption, and is an Associated Institute of the...more
The Financial Action Task Force has published the outcomes of its third and last Plenary meeting under the U.S. Presidency in Orlando on June 19-21, 2019. The FATF considered key issues such as strategic initiatives, mutual...more
The Financial Action Task Force has published a Report to G20 Finance Ministers and Central Bank Governors on its ongoing work to fight money laundering and terrorist financing. The report summarizes the FATF's work...more
Relief is Narrow, but FinCEN’s Explanation of Low Money Laundering Risk Posed by Lending Products is Instructive - On May 11, the Financial Crimes Enforcement Network (“FinCEN”) issued a ruling to provide exceptive relief...more
It’s not just your taxes that are due each year on April 15. For financial institutions, this coming April 15 is the date the New York Department of Financial Services’ (NYDFS’s ) new Anti-Money Laundering (AML) Part 504...more
Today, I want to take a deep dive and exploration of the levels of due diligence. Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of...more
The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more
On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more
On October 21, 2015, the Joint Committee of the European Securities and Markets Authority, the European Banking Authority and the European Insurance and Occupational Pensions Authority (together, the European Supervisory...more
Regulatory Developments: CFTC Grants Temporary Registration as SEF to LedgerX Bitcoin Options Exchange and Clearing House - On Sept. 10 the CFTC announced that it had issued an Order of Temporary Registration as a...more
In preparation for the audit of Canada’s anti-money laundering and terrorist financing regime by the Financial Action Task Force (FATF) in the fall of 2015, the Department of Finance and the Financial Transactions and Reports...more