On December 23, the Financial Crimes Enforcement Network (FinCEN) published a final rule amending the Bank Secrecy Act civil penalty regulations concerning requirements for reporting foreign financial accounts and...more
The U.S. Supreme Court began its new term last week and is poised to answer some major questions in criminal and regulatory law. This term, the Court is tasked with construing the Bank Secrecy Act’s penalty provision, ruling...more
On July 29, 2021, the United States Attorney for the Southern District of New York, the Assistant Attorney General for the Department of Justice Tax Division, and the IRS Commissioner all announced that a federal court in New...more
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more
Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more
On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more