Republicans have swept the 2024 elections, returning Donald Trump to the White House as the 47th President and flipping the Senate to a Republican majority. Having narrowly maintained control of the House of Representatives,...more
12/11/2024
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On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more
9/10/2024
/ AML/CFT ,
Anti-Money Laundering ,
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The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers -
The Securities and Exchange Commission (“SEC”) and the...more
5/24/2024
/ AML/CFT ,
Bank Secrecy Act ,
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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 ,
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Section 3(a)(5) of the Securities Exchange Act of 1934, as amended (the “Securities Exchange Act”) defines a “dealer” as “any person engaged in the business of buying and selling securities […] for such person’s own account...more
Financial Industry Regulatory Authority (“FINRA”) supervisory control rules require each securities broker-dealer that is a member of FINRA to categorize every location from which the business of the broker-dealer is...more
AML Developments - What You Need to Know -
Earlier this month, the New York State Department of Financial Services (“DFS”) and the Federal Reserve Board of Governors (“FRB”) announced settlements with the Industrial and...more
AML Developments - What You Need to Know -
On November 21, 2023, the U.S. Justice Department unsealed charges against cryptocurrency exchange Binance and Binance CEO Changpeng Zhao for violating anti-money laundering...more
11/27/2023
/ Anti-Money Laundering ,
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Two Recent Decisions Throw Cold Water on Investors’ Ability to Get Their Premiums Back on Policies Deemed Void Ab Initio -
In the latter half of 2022, the Seventh Circuit Court of Appeals and the Delaware Supreme Court—two...more
In Cost of Insurance Litigation, Courts Continue to Disagree Over the Meaning of the Key Contractual Provision -
If you see a movie that is “based on a true story,” how close to the story are you expecting the movie to be?...more