On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that will define most SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) as...more
10/16/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Compliance ,
FinCEN ,
Foreign Private Issuers ,
Investment Advisers Act of 1940 ,
Money Laundering ,
Mutual Funds ,
Policies and Procedures ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Travel Rule
Background -
The Corporate Transparency Act of 2019 (“CTA”) became effective on January 1, 2024. Under the CTA, all “reporting companies” must file a Beneficial Ownership Information (BOI) report with the Financial Crimes...more
8/1/2024
/ Beneficial Owner ,
Corporate Transparency Act ,
Disclosure Requirements ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Fines ,
Noncompliance ,
Penalties ,
Popular ,
Reporting Requirements ,
Sanctions
On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more
8/25/2020
/ Arms Length Transactions ,
Capital Gains ,
Capital Investments ,
Carried Interest ,
Fund Managers ,
Holding Periods ,
Income Taxes ,
Investment Adviser ,
Investment Management ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Popular ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On April 16, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert summarizing numerous issues it found in its recent examinations of SEC-registered...more
5/2/2019
/ Broker-Dealer ,
Customer Privacy ,
Data Privacy ,
Data Protection ,
Enforcement Actions ,
Investor Protection ,
OCIE ,
Personally Identifiable Information ,
Privacy Notice Rule ,
Registered Investment Advisors ,
Regulation S-P ,
Risk Alert ,
Securities and Exchange Commission (SEC)