On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more
The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures. As we...more
1/29/2025
/ AML/CFT ,
Anti-Money Laundering ,
Compliance ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Penalties ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more
9/17/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
National Security ,
Registered Investment Advisors
On April 17, 2023, the Wolfsberg Group (the "Group") issued updated guidelines for financial institutions ("FI") relating to Anti-Bribery and Corruption ("ABC") Compliance Programs. Although the guidance is not binding, it...more
In February 2023, the Financial Action Task Force (“FATF”), the global standard-setter on Anti-Money Laundering policy, issued a report describing the financial crime risks in the art and antiquities market, as well as good...more