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SEC and FinCEN Propose Rules to Impose Customer Identification Program Obligations on Certain Investment Advisers

On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more

FinCEN Proposes AML/CFT Rules for Investment Advisers

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Compliance Impact of FinCEN Statement of Priorities

At the direction of the President, FinCEN is intensifying its regulation of banks and fintechs across the spectrum of the laws that it is charged with enforcing. This past June, the White House published the Memorandum on...more

Sharper Lines Mean Tighter Nets: How the FinCEN’s Latest Priorities are Another Step to Increased Enforcement

In the latest sign that the federal enforcement apparatus is slowly but surely training its sights on white-collar professionals and businesses, particularly financial services, the Financial Crimes Enforcement Network...more

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