The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more
Last week, the U.S. Department of the Treasury released a report entitled “Study of the Facilitation of Money Laundering and Terror Finance Through the Trade in Works of Art” that discussed risks in the art sales ecosystem,...more
The 2020 National Strategy for Combating Terrorist and Other Illicit Financing was issued earlier this month by the U.S. Department of the Treasury. Prepared in consultation with regulators and law enforcement, including the...more
On June 30, 2016, the New York Department of Financial Services (“NY DFS”) adopted a final anti-terrorism and anti-money laundering regulation (the “Final Regulation”) that requires institutions subject to regulation by the...more
Regulatory Developments - NY DFS Adopts Final Anti-Terrorism Program Regulation - On June 30, New York’s Department of Financial Services (DFS) adopted a risk-based anti-terrorism and anti-money laundering...more
Earlier this month, Governor Andrew M. Cuomo of New York announced newly proposed anti-terrorism and anti-money laundering regulations that impose increased compliance requirements and more importantly, vastly expanded...more