The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector -
Regulators have long considered the lack of anti-money...more
2/27/2024
/ AML/CFT ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Compliance ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Exempt Reporting Advisers (ERAs) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Law Enforcement ,
Patriot Act ,
Policies and Procedures ,
Proposed Rules ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Third-Party Service Provider
Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry -
On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more
10/26/2021
/ Audits ,
Cryptocurrency ,
Cybersecurity ,
FinCEN ,
Internal Controls ,
Money Laundering ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Assessment ,
Sanctions ,
Testing Requirements ,
Training ,
U.S. Treasury ,
Virtual Currency
FinCEN announces eight areas of focus and advises preparation for issuance of new regulations -
On June 30, 2021, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the first...more
7/8/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Corporate Transparency Act ,
Corruption ,
Cyber Crimes ,
Cybersecurity ,
Drug Trafficking ,
Financial Institutions ,
FinCEN ,
Fraud ,
Human Trafficking ,
New Regulations ,
Popular ,
Reporting Requirements ,
Significant Transnational Criminal Organization ,
Terrorism Funding ,
Virtual Currency ,
Whistleblowers
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers