Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more
The CFTC’s proposed rules specify that certain event contracts involving gaming (such as political contests, awards contests, and sports competitions), war, terrorism, assassination, and unlawful activities under federal or...more
A new regulation under the federal Corporate Transparency Act (CTA) that, for the first time, will require disclosure of information about all U.S. formed corporations, limited liability companies, and limited partnerships...more
The Corporate Transparency Act (31 USC §5336) goes into effect January 1, 2024. Under the Act, most LLCs (and other entities) will need to supply basic personal identification data regarding their “beneficial owners” to...more
Financial Crimes Enforcement Network (FinCEN) remains committed to combating money laundering, in all forms, in connection with the banking and financial systems. To this end, on June 30, 2021, FinCEN issued new...more
A new proposal would subject financial institutions and exchanges to onerous recordkeeping and reporting requirements for certain digital currency transactions. In a surprise release in the waning days of the Trump...more
First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime - Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more
On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses. The updated policy now offers voluntary...more
Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more