News & Analysis as of September 23, 2024

FinCEN › No-Action Letters

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

Pillsbury Winthrop Shaw Pittman LLP on 3/15/2024

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

FinCEN Seeks Public Comments on No-Action Letters

Ballard Spahr LLP on 6/9/2022

On June 3, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advance Notice of Proposed Rulemaking (“ANPRM”) that seeks public comment on the implementation of a “no-action letter” process at FinCEN. The...more

FinCEN Proposes No-Action Letter Process

McGuireWoods LLP on 6/9/2022

On June 3, 2022, the Financial Crimes Enforcement Network (FinCen) issued an Advance Notice of Proposed Rulemaking proposing public comment on the enactment of a no-action letter process. This Advanced Notice follows...more

FinCEN Weighs Path to a No-Action Letter Process

Morrison & Foerster LLP on 6/6/2022

On Friday, FinCEN published an Advance Notice of Proposed Rulemaking (ANPRM) as it further considers implementing a no-action letter process related to anti-money laundering compliance. The ANPRM follows a 2021 FinCEN...more

FinCEN Pursues Its Next Steps, Posting its Priorities and Pondering a No-Action Process

Orrick, Herrington & Sutcliffe LLP on 7/29/2021

The Financial Crimes Enforcement Network (FinCEN) has completed two of its early benchmark obligations arising out of the recently passed Anti-Money Laundering Act of 2020 (the “AML Act”)... First, pursuant to the AML Act,...more

House Votes to Repeal OCC True Lender Rule

Goodwin on 7/28/2021

In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

WilmerHale on 7/15/2021

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

FinCEN issues assessment on possible “no-action” letters for industry

Ballard Spahr LLP on 7/9/2021

As required by the Anti-Money Laundering Act (“AML Act”), the Financial Crimes Enforcement Network (“FinCEN”) issued on June 30, 2021 its 14-page assessment regarding the feasibility of FinCEN issuing so-called “no-action”...more

2020 Digital Asset Regulatory Lookback (US Edition)

Latham & Watkins LLP on 1/22/2021

Regulators once again offered piecemeal guidance, while focusing on risks and enforcement. Meanwhile, innovation and institutional adoption took off. Last year, Latham & Watkins sounded a hopeful note that 2020 would provide...more

CFPB Grants No-Action Letter for Proposed Small-Dollar Credit Product

Goodwin on 11/12/2020

In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more

Financial Services Report, Fall 2019

Morrison & Foerster LLP on 9/12/2019

We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more

Proposed AML Reforms Aim to Enhance and Modernize AML/CFT Enforcement

Ballard Spahr LLP on 6/28/2019

Second Post in a Two-Post Series on the ILLICIT CASH Act - A discussion draft of legislation recently introduced in the Senate, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal...more

Financial Services Weekly Roundup - June 2018 #2

Goodwin on 6/14/2018

Editor's Note - In This Issue. The Securities and Exchange Commission (SEC) issued a no-action letter that closes the gap in investor protection created by the SEC’s approval of FINRA Rule 2165; the SEC’s Investment...more

Financial Services Weekly News - December 2015

Goodwin on 12/4/2015

Regulatory Developments - SEC Grants Exemption from Registration as a Clearing Agency to Two Matching Service Providers - On Nov. 24 the SEC approved applications by Bloomberg STP LLC and SS&C Technologies, Inc....more

Financial Services Weekly News Roundup - June 2015 #3

Goodwin on 6/18/2015

Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more

SEC Extends No-Action Letter Permitting Broker-Dealers to Rely on Certain Investment Advisers to Conduct Customer Identification...

Katten Muchin Rosenman LLP on 1/22/2013

The Securities and Exchange Commission has extended a no-action letter dated February 12, 2004 (the 2004 Letter) from the Securities Industry Financial Markets Association (SIFMA) that permits broker-dealers, subject to...more

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FinCEN › No-Action Letters

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