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Money Laundering Investment Adviser

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Katten Muchin Rosenman LLP

AML Programs for Investment Advisers

On August 28, the US Department of the Treasury’s (Treasury Department) Financial Crimes Enforcement Network (FinCEN) issued a final rule that expands anti-money laundering (AML) and countering the financing of terrorism...more

ArentFox Schiff

SEC and FinCEN Propose New Rule: Mandatory Customer Verification for Investment Advisers in 2024

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On May 13, the US Securities and Exchange Commission (SEC) and the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) jointly released a notice of proposed rulemaking (NPRM) which, if...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Woodruff Sawyer

Only You (Investment Advisers)! Can Prevent Money Laundering

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If you are an investment manager and you significantly and repeatedly outperform the market, your investors will lavish you with righteous praise and your firm will shower you with well-deserved riches....more

Seward & Kissel LLP

FinCEN Proposes New Rule to Subject Advisers to AML Requirements

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Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...more

Troutman Pepper

FinCEN Proposes New Investment Adviser AML Rule

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On February 1/3, the Financial Crimes Enforcement Network (FinCEN) proposed a new rule (the Proposed Rule), that, if adopted, would add certain investment advisers to the definition of “financial institution” under the Bank...more

Wilson Sonsini Goodrich & Rosati

FinCEN Proposes Significant Expansion of AML/CFT Obligations to Cover Registered Investment Advisers, Venture Capital Advisers,...

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a sweeping expansion of the Bank Secrecy Act’s (BSA) affirmative anti-money laundering (AML) and countering the financing of...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

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On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Mayer Brown

Third Time’s the Charm? Anti-Money Laundering Compliance Requirements Proposed for Registered and Exempt Reporting Investment...

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On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more

Troutman Pepper

FinCEN Proposes Extending AML/CFT Requirements to Certain Investment Advisors

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently announced a Notice of Proposed Rulemaking (NPRM) aimed at keeping bad actors from exploiting the U.S. financial system and assets...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules in Q1 2024

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Mintz Edge

FinCen Publishes Final Rule on Beneficial Ownership Requirements - a Critical Step Towards Heightened Transparency in U.S....

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On January 1, 2021, Congress passed the Corporate Transparency Act (“CTA” or the “Act”) to “better enable critical national security, intelligence and law enforcement efforts to counter money laundering, financing of...more

Manatt, Phelps & Phillips, LLP

The Government’s New Strategy To Counter Corruption: What You Need To Know

On June 3, 2021, the White House issued a memorandum formally establishing the fight against corruption as a core national security interest. The memorandum directed the development of a presidential strategy to, among other...more

Goodwin

Northern District of California Dismisses Shareholder Derivative Suit Concerning Lack of Diversity

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Northern District of California Dismisses Shareholder Derivative Suit Concerning Lack of Diversity; Delaware Court of Chancery Dismisses Stockholder Suit Against Medical Device Company for Failure to Plead Demand Futility;...more

Miller Canfield

SEC Annual Examination Priorities for RIAs

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Last month, the SEC Division of Examinations (the "Division"; formerly the "Office of Compliance Inspections and Examinations") released its annual Examination Priorities for 2021. RIAs and their Chief Compliance Officers are...more

A&O Shearman

Motion To Dismiss Filed In Eastern District Of New York Case Could Provide Opportunity For Clarity On Scope Of FCPA's "Internal...

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On November 20, 2020, lawyers for a former investment banker, indicted in the United States District Court for the Eastern District of New York for his alleged role in the 1MDB matter, filed a Motion to Dismiss (“MTD”) the...more

Kramer Levin Naftalis & Frankel LLP

OCIE Releases 2020 Examination Priorities

The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) published its 2020 Examination Priorities, an annual publication that enhances transparency and provides insights into...more

Robinson & Cole LLP

Data Privacy + Cybersecurity Insider - May 2019 #4

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The North American Securities Administrators Association (NASAA) this week approved an information security model rule package aimed at improving the cybersecurity posture of the 17,543 state-registered advisers. ...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

SEC Proposes to Enhance Protections and Preserve Choice for Retail Investors in Their Relationships with Investment Professionals - On April 18, the Securities and Exchange Commission voted to propose a package of...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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FinCEN is extending its campaign to press title insurance companies to reveal the real buyers behind shell companies that pay cash for high-end real estate deals in select cities around the country....more

Ballard Spahr LLP

Investment Management Update - October 2015

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Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Troutman Pepper

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

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The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

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