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Silicon Valley Bank Fallout: Navigating and Managing the Account Opening Processes at Other Financial Institutions

Silicon Valley Bank, Santa Clara, California, was closed on March 10 by the California Department of Financial Protection and Innovation (CDFPI). On March 12, the New York State Department of Financial Services (NYSDFS)...more

AML Best Practices for Private Fund Managers: The Prudence of Establishing an AML Compliance Program

I. Introduction- U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds),1 and their U.S. general partners, sponsors, and managers (Advisers), are not directly subject to the...more

FinCEN Issues Historic Order Against Virtual Currency Exchange Facilitating Russian Illicit Finance

On January 18th, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first action (the Order) pursuant to Section 9714 of the Combating Russian Money Laundering Act1 to designate...more

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