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FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

OFAC Amends Cuba Sanctions, Loosening Restrictions and Fully Implementing Biden Administration’s Cuba Policy

On May 28, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to 31 C.F.R. Part 515, the Cuban Assets Control Regulations (CACR), expanding access to certain financial and...more

FinCEN Re-Proposes AML/CFT Requirements Covering Investment Advisers

On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

Crypto Currently: California Enacts Landmark Crypto Licensing Law

On October 13, Governor Gavin Newsom signed into law a comprehensive licensing regime for digital asset companies operating in California. Until this point, California had refrained from taking a definitive position on...more

Ready to Report: Complying with FinCEN’s New Beneficial Ownership Rule Under the CTA

Although the Corporate Transparency Act’s (“CTA”) new beneficial ownership rule goes into effect on January 1, 2024, recent polling suggests that many businesses remain either unaware of these upcoming reporting obligations...more

2023 Venture Capital Report

US Market Review and Outlook - Venture capital financing and liquidity activity contracted in 2022 from the record-breaking levels of the prior year, in the face of declining equity markets, rising interest rates and...more

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