FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more
3/15/2024
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
CDD ,
CFIUS ,
China ,
Customer Identification Program (CIP) ,
Due Diligence ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
FinCEN ,
Infrastructure ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investors ,
No-Action Letters ,
Popular ,
Private Funds ,
Proposed Rules ,
Risk Assessment ,
Russia ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
Suspicious Activity Reports (SARs) ,
Technology Sector
The Biden Administration has launched a comprehensive effort to develop a cohesive policy approach for digital assets.
Key agencies are instructed to report on digital asset issues and legal framework in relation to...more
3/14/2022
/ Anti-Money Laundering ,
Biden Administration ,
Central Bank Digital Currency (CBDCs) ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Non-Fungible Tokens (NFTs) ,
Securities ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
Despite months of posturing and growing geopolitical tensions, Russia’s full-scale invasion of Ukraine this week was a shock to the global community. Western leaders have been swift and unanimous in their response, condemning...more
2/28/2022
/ Anti-Money Laundering ,
Asset Freeze ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
The Biden Administration has signaled an expanded commitment to longstanding U.S. anti-corruption policies, and recent enforcement actions and policy announcements provide insights into what foreign officials, companies and...more
As the Biden Administration commits to crack down on corruption, recent enforcement actions show the DOJ continues a longstanding trend of relying on AML laws and other alternate statutes to prosecute corruption cases, with...more
7/14/2021
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
RICO ,
Travel Act ,
Wire Fraud
One portion of the National Defense Authorization Act creates a federal beneficial ownership registry, with reporting requirements for corporations, LLCs and “other similar entities.”
The Corporate Transparency Act creates...more
1/7/2021
/ Anti-Money Laundering ,
Compliance ,
Control Test ,
Disclosure Requirements ,
FinCEN ,
Fund Sponsors ,
Investors ,
NDAA ,
Real Estate Development ,
Reporting Requirements ,
Standard Operating Procedures ,
Transparency
New federal requirements in the annual national defense budget reauthorization effectively will end anonymous U.S. shell companies by requiring businesses to disclose 25 percent owners and control persons to a newly created...more
1/6/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Drug Trafficking ,
Financial Institutions ,
FinCEN ,
Fraud ,
Guidance Update ,
Human Trafficking ,
Law Enforcement ,
Patriot Act ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations ,
Terrorist Acts ,
U.S. Treasury ,
Virtual Currency ,
Whistleblowers
BitMEX, a Seychelles-based centralized exchange for trading derivatives on bitcoin, ether and litecoin, and certain of its executives have been charged with a number of violations under the U.S. Commodity Exchange Act (CEA),...more
10/8/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
CFTC ,
Commodity Exchange Act (CEA) ,
Department of Justice (DOJ) ,
Digital Assets ,
Due Diligence ,
Ether ,
Futures Commission Merchants (FCMs) ,
Geo-Blocking ,
SEFs ,
Trading Platforms ,
U.S. Customs
On May 8, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) reissued its Geographic Targeting Orders (GTOs) for 12 metropolitan areas. ...more
If past crises are any guide, public outcry for accountability, media attention and vigorous enforcement is likely in the wake of the pandemic.
Corruption, fraud and money laundering are ever-present risks during the...more
Federal regulators start to address some of the recent questions about digital assets such as tokens and virtual currencies, though many questions remain.
U.S. Regulators and Congress are grappling with how to manage the...more
9/12/2019
/ Anti-Money Laundering ,
Asset Tokens ,
Commodities ,
Cryptocurrency ,
Digital Assets ,
Financial Industry Regulatory Authority (FINRA) ,
Howey ,
Know Your Customers ,
Legislative Agendas ,
No-Action Letters ,
Regulatory Agencies ,
Regulatory Agenda ,
Securities ,
Securities and Exchange Commission (SEC) ,
Utility Tokens ,
Virtual Currency
As it targets terrorist groups and their finances, the U.S. Government announces potent secondary sanctions that can impede correspondent banking relationships of non-U.S. banks.
A new U.S. Executive Order updates the...more
9/12/2019
/ Anti-Money Laundering ,
Due Diligence ,
Entity List ,
Executive Orders ,
Financial Institutions ,
Foreign Banks ,
Non-Bank Lenders ,
SDN List ,
Terrorism Funding ,
Terrorist Financing Regulations ,
U.S. Treasury
On June 29, 2017, the U.S. Treasury Department announced new steps applying pressure on North Korea in relation to its proliferation activities. Specifically, this involved (1) sanctions designations against Chinese shipping...more
Policy makers in Europe continue to explore responses to the Panama Papers revelations and recent terrorist attacks. On 28 February, European law makers approved important amendments to the EU’s Anti-Money Laundering (AML)...more
On September 15, 2016, President Obama announced that U.S. economic sanctions on Myanmar (also known as Burma) would end, but the announcement left many questions as to what would change and what sanctions might remain. On...more
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015 which, among other things, would add SEC-registered investment advisers to the “financial...more
9/2/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
In This Issue:
- Preface
- Chapter 1 Choice Of A Business Entity
- Chapter 2 Introduction To Federal Securities Laws
- Chapter 3 From Let’S Go Shopping To Closing: U.S. M&A Process
- Chapter 4...more
4/17/2013
/ Anti-Bribery ,
Anti-Dumping Duty ,
Anti-Money Laundering ,
Commercial Real Estate Market ,
Corporate Governance ,
Corporate Taxes ,
Dodd-Frank ,
Environmental Policies ,
Fair Labor Standards Act (FLSA) ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Limited Liability Company (LLC) ,
Partnerships ,
Proxy Voting Guidelines ,
Regulation FD ,
Renewable Energy ,
Reporting Requirements ,
Sarbanes-Oxley ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Tax Liability