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Who may be interested: Investment Advisers - Quick Take: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule subjecting certain registered investment advisers (RIAs) and...more
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more
On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more
The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more
Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more
On 12 June 2024, K2 Integrity and Schulte Roth & Zabel hosted a webinar discussing new regulatory obligations anticipated under proposed rules for investment advisers (IAs), timelines for finalization and compliance, and how...more
Treasury proposed a new rule that would require investment advisers to establish an AML/CFT program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Proposed Rule). The Proposed Rule...more
On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more
On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more
The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more
According to reports, a major U.S.-based global investment bank has allowed a borrower to use bitcoin as collateral for a cash loan, for the first time in the bank’s history. In other financial news, according to reports, the...more
In a few short weeks, the global loss attributable to cybercrime is expected to surpass $6 trillion.* Therefore, in an effort to protect financial institutions and consumers from further loss, agencies including the United...more
In perhaps the last major legislative action under this presidential administration, on New Year’s Day 2021, Congress passed—over President Trump’s veto—what could be the most significant anti-money laundering (AML) statute...more
On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, which includes the Corporate Transparency Act (the CTA).1 The CTA requires all U.S. businesses to file “beneficial ownership”...more
The Commission periodically has filed enforcement actions against broker-dealers for failing to file SARs - suspicious activity reports - typically centered on a failure to file reports regarding microcap issuers. Those...more
On May 1, 2020, the Federal Bureau of Investigation issued an intelligence bulletin warning, reported on in late July by several members of the media, concerning the use by threat actors of the “private placement of funds,...more
Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more
Seeking to close a perceived “gap” in regulations intended to facilitate the government’s efforts to curb money laundering and the financing of terrorism, the U.S. Department of the Treasury’s Financial Crimes Enforcement...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
Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more
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
On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more
Jacqui Merrill, an Associate at The Volkov Law Group, joins us with a posting on the SEC’s request for increased access to emails. In a Senate Judiciary Committee meeting held on September 16, 2015, Securities and...more
On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more
After more than a decade of delay, the Financial Crimes Enforcement Network (FinCEN) of the Department of Treasury issued a notice of proposed rulemaking that would require registered investment advisers to establish...more