Sometimes a comprehensive overview is needed to recognize that individual anomalous conduct is indicative of a criminal scheme. Recently, the Department of Financial Services (DFS) looked at an unusual pattern of interaction...more
In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more
For many in the Funds Industry, the issue on 20 October 2020 of the Central Bank of Ireland’s (the “Central Bank”) Industry Letter (the “Industry Letter”) relating to the Central Bank’s Thematic Review of Fund Management...more
In separate “Industry Letters” addressed to “The Chief Executive Officers or the Equivalents of New York State Regulated Institutions,” the New York Department of Financial Services (NYDFS) has mandated that regulated...more
On December 23, 2019, the New York Department of Financial Services (NYDFS) issued an Industry Letter instructing each institution it regulates, including banks and licensed Fintechs, to make submissions describing the...more