On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking,...more
Recent developments in the world of crypto have come at a rapid pace to open 2025 not only signaling but, in some instances, explicitly declaring the Trump Administration’s intent to significantly relax or eliminate...more
3/10/2025
/ Anti-Money Laundering ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Executive Orders ,
Financial Regulatory Reform ,
FinCEN ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Trump Administration
This week, the Federal Reserve’s Federal Open Markets Committee (FOMC) decided that its target policy rate range would decrease by 50 basis points, resulting in a new target range for the Federal Funds Rate of 4.75 percent to...more
In the first half of 2024, the Financial Industry Regulatory Authority (FINRA) issued several fines and suspensions against participants in the municipal market, including for violations of its registration, reporting,...more
7/26/2024
/ Broker-Dealer ,
Department of Justice (DOJ) ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
MSRB ,
Municipal Securities Market ,
Proposed Rules ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
After years of anticipation, the Corporate Transparency Act (the CTA) officially went into effect on January 1, 2024. Now that we are two months into the CTA era, below are a few updates and recommended action items based on...more
3/8/2024
/ Beneficial Owner ,
Congressional Authority ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Disclosure Requirements ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Lack of Authority ,
Limited Liability Company (LLC)
New York State’s LLC Transparency Act, that will come into effect December 21, 2024, complements the Federal Corporate Transparency Act by requiring New York limited liability companies and foreign limited liability companies...more
The start of calendar year 2024 will bring a new reporting obligation for approximately 32.5 million business organizations. Under the Corporate Transparency Act, covered companies and their senior officers must obtain...more
1. What Is the Corporate Transparency Act and Why Was It Enacted? Congress enacted the Corporate Transparency Act (CTA) on January 1, 2021, to address concerns that the inaccessibility of U.S. companies’ beneficial ownership...more
12/5/2023
/ Beneficial Owner ,
Corporate Transparency Act ,
Filing Requirements ,
Financial Crimes ,
Financial Services Industry ,
FinCEN ,
Limited Liability Company (LLC) ,
PCAOB ,
Personal Information ,
Reporting Requirements ,
Subsidiaries ,
Tax Exemptions ,
Trustees
On November 16, the Financial Crimes Enforcement Network (“FinCEN”) issued – again –expanded FAQs pertaining to beneficial ownership information (“BOI”) reportable under the Corporate Transparency Act (“CTA”). These expanded...more
11/17/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
FinCEN ,
Lenders ,
Mortgage Lenders ,
Popular ,
Proposed Legislation ,
Reporting Requirements
Beginning on January 1, 2024, many U.S. legal entities and foreign entities registered to do business in the U.S. will be required to report information about themselves, their beneficial owners, and their company applicants...more
10/26/2023
/ Acquisitions ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Business Ownership ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Filing Requirements ,
Financial Institutions ,
FinCEN ,
Legal Entities ,
Popular ,
Reporting Requirements ,
Securities Exchange Act of 1934
The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”). They pertain, in part, to a proposed extension of the filing deadline for certain...more
10/2/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Comment Period ,
Corporate Transparency Act ,
Filing Deadlines ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
National Security ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as...more
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The United States Court of Appeals for the Second Circuit upheld on August 24, 2023, a decision from the District Court to dismiss a securities fraud case brought by a Chapter 11 bankruptcy trustee, on the...more
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As a result of the shift from LIBOR to the Secured Overnight Finance Rate (SOFR), borrowers who use interest rate swaps or options to manage interest rate risk may be asked to pay extra to maintain a hedge under...more
6/13/2023
/ Alternative Reference Rates Committee (ARRC) ,
Bank Loan Markets ,
Borrowers ,
CFTC ,
Consumer Financial Products ,
Financial Services Industry ,
Lenders ,
Libor ,
Loans ,
Proposed Legislation ,
Secured Overnight Funding Rate (SOFR)
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The UK Financial Conduct Authority (FCA) recently announced the results of its November 2022 consultation on synthetic USD LIBOR. In line with the FCA consultation, USD LIBOR will continue to be published by the...more
The recent collapse of Silicon Valley Bank has caused concern across the country among investors, consumers, and businesses. Today, our lawyers recap on the series of events that unfolded since March 10, 2023, and answer the...more
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The past four days have been a roller coaster for many investors; the events of Friday, March 10, that saw the largest failure of a bank since 2008, have put many on edge. On Sunday, the Fed, Treasury, and FDIC...more
On January 23, 2023, the New York Department of Financial Services (NYDFS) published a short but important notice to virtual currency asset custodians containing guidance on custodial structures in order to protect customers...more
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The Federal Reserve Board last week adopted a final rule that implements the Adjustable Interest Rate (LIBOR) Act (the LIBOR Act). The LIBOR Act identifies benchmark rates based on the Secured Overnight Financing...more
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The United Kingdom Financial Conduct Authority (FCA) on November 23 published its Consultation on ‘Synthetic’ U.S. Dollar LIBOR to advance some synthetic applications of USD LIBOR from June 30, 2023, until...more
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The jurisdictional lines between the different types of digital assets remain unclear. As Congress weighs separate bills seeking to establish a clear and workable regulatory framework, market participants are...more
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The Security and Exchange Commission last month released a Risk Alert to notify municipal advisors of key compliance issues. The SEC’s Division of Examinations adds client disclosure concerns to the list of most...more
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U.S. Senators Debbie Stabenow (D-Mich.) and John Boozman (R-Ark.) of the Senate Agricultural Committee have formally proposed a new bill to regulate the digital asset market. The Digital Commodities Consumer...more
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The Alternative Reference Rate Committee (ARRC), convened by the Federal Reserve Board and the New York Fed to help ensure a successful transition from LIBOR to SOFR, this week published its LIBOR Legacy...more
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Significant federal regulation may be coming soon for cryptocurrencies, blockchain, and non-fungible tokens (NFTs). On June 6, 2022, U.S. Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced...more