After two decades and three proposed rulemakings on whether investment advisers should have anti-money laundering (AML) and countering the financing of terrorism (CFT) program requirements and attempting to identify the...more
10/8/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
Corporate Counsel ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
Implementation of the Corporate Transparency Act (CTA)[1] is gathering momentum. Most notably, as of the new year the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) is accepting reports of...more
As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more
The Corporate Transparency Act (CTA), passed over President Trump's veto as part of the National Defense Authorization Act on January 1, 2021, may have a major impact on the manner in which financial institutions comply with...more
Have you ever been depressed when a Kickstarter project to make potato salad proceeded to rake in more than your annual salary? Felt a sense of despair as an Indiegogo campaign to develop an X-rated card game went on to...more
On May 5, Ripple Labs (Ripple) entered into a consent decree with the Financial Crimes Enforcement Network (FinCEN), under which Ripple admitted to conduct that violated U.S. anti-money laundering (AML) laws and agreed to...more