News & Analysis as of

BSA/AML Securities and Exchange Commission (SEC) Customer Identification Program (CIP)

Royer Cooper Cohen Braunfeld LLC

SEC & FinCEN Propose Customer Identification Program Requirements

A press release was recently issued describing a significant joint proposal by the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The proposal...more

Ballard Spahr LLP

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

Ballard Spahr LLP on

Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...more

Cadwalader, Wickersham & Taft LLP

FinCEN Proposes New Rule Requiring AML Compliance Programs for Investment Advisers

On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more

Troutman Pepper

SEC’s 2024 Examination Priorities: Cryptocurrency, Emerging Tech, and AML

Troutman Pepper on

As reported in more detail on our Regulatory Oversight blog, the Securities and Exchange Commission’s Division of Examinations recently released its 2024 Examination Priorities report. The report underscores the SEC’s intent...more

Troutman Pepper

SEC’s 2024 Examination Priorities: Implications for Consumer Financial Services

Troutman Pepper on

The Securities and Exchange Commission’s Division of Examinations has outlined its 2024 Examination Priorities, with a significant focus on cryptocurrency, emerging technology, and Anti-Money Laundering (AML) laws. This has...more

Ballard Spahr LLP

SEC Issues Alert Outlining Deficiencies in Broker-Dealers’ AML Compliance

Ballard Spahr LLP on

On July 31, 2023, the United States Securities and Exchange Commission (“SEC”) published an alert outlining deficiencies the Department of Examinations has observed in broker-dealers’ (“BD”) compliance with anti-money...more

Ballard Spahr LLP

SDNY Unveils First Criminal Prosecution of Broker-Dealer for Violating BSA

Ballard Spahr LLP on

For the first time, a broker-dealer, Central States Capital Markets, LLC (Central States), has been prosecuted for violating the Bank Secrecy Act (BSA). ...more

BCLP

Recent Developments Confirm AML is a Regulatory "Hot Button"

BCLP on

The SEC continues to reiterate the role of broker-dealers as “gatekeepers to the securities markets” by focusing on firms’ anti-money laundering (“AML”) obligation. The import that the SEC, as well as FINRA, places on firms’...more

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