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Policies and Procedures Beneficial Owner

SEC Compliance Consultants, Inc. (SEC³)

Lessons From 2024: Tips for Private Fund Managers

As we look back on the SEC’s actions in 2024, we wanted to share our thoughts on lessons learned that we believe will carry through to 2025....more

Seward & Kissel LLP

Annual Report and Shareholder Meeting Season and Other Recent SEC Developments

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This memorandum summarizes key U.S. Securities and Exchange Commission (“SEC”) and stock exchange regulatory filing deadlines, new disclosure requirements and general tips and guidance for both U.S. domestic issuers and for...more

Ankura

Identity Theft and How To Prevent It

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Imagine sitting in your living room, enjoying a cup of your favorite morning coffee, and you open your mail to discover that you recently opened a new bank account at XYZ Bank, unbeknownst to you. Or maybe you receive an...more

Morrison & Foerster LLP

Finish Strong and Looking Ahead

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As the end of 2024 approaches, it is crucial that all investment advisers—including registered investment advisers (RIAs) and exempt reporting advisers (ERAs)—complete end of the year regulatory and compliance tasks and...more

Holland & Hart LLP

The Corporate Transparency Act Compliance Deadline Looms—Lenders, Are Your Customers Ready? Are YOU Ready?

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The January 1, 2025, deadline imposed by the Corporate Transparency Act (CTA) for all “reporting companies” formed prior to 2024 to file their initial beneficial ownership reports with FinCEN is rapidly approaching. Given the...more

Husch Blackwell LLP

SEC Levies Extensive Penalties for Late Beneficial Ownership Reporting and Insider Transaction Reports

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On September 25, 2024, the Securities and Exchange Commission (SEC) announced settlements with 23 entities and individuals for untimely reporting related to their respective holdings and transactions in public company stock....more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

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The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Conyers

Regulatory & Risk Advisory Review: Cayman Islands - April to June 2024

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Welcome to the second instalment of 2024 of the Regulatory & Risk Advisory Review. In this edition we cover several Cayman Islands regulatory updates including updates to the Beneficial Ownership Transparency Act, the...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

Bracewell LLP

Beneficial Ownership Information Reporting Under the Corporate Transparency Act

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On January 1, 2024, the reporting requirements under the Corporate Transparency Act (CTA) became effective. The CTA was enacted by Congress on January 1, 2021, as part of the Anti-Money Laundering Act of 2020 and requires...more

Foley Hoag LLP

The Corporate Transparency Act: An Overview of the Impact on Private Funds

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What is the purpose of the Corporate Transparency Act (“CTA”)? Effective as of January 1, 2024, the Corporate Transparency Act (“CTA”) imposed new federal reporting obligations on certain companies, including potentially...more

Eversheds Sutherland (US) LLP

Key highlights of FinCEN’s final rule on access to Beneficial Ownership Information

The Financial Crimes Enforcement Network (FinCEN) issued the Beneficial Ownership Information Access and Safeguards Rule (Access Rule) establishing the framework for access to and protection of beneficial ownership...more

Perkins Coie

Corporate Transparency Act Will Require Disclosure of Senior Officers and Directors of Many US and Foreign Companies

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The Corporate Transparency Act (CTA) became law on January 1, 2021, and requires companies formed and/or operating in the United States to disclose beneficial ownership information through a database that will be maintained...more

Verrill

Who Must Be Reported as Beneficial Owners of a Reporting Company?

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In 2024 the Corporate Transparency Act (CTA) and related CTA Rule will require more than 30 million “Reporting Companies” to register with FinCEN, a bureau of U.S. Treasury. Registration occurs through online filings of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Spilman Thomas & Battle, PLLC

SuperVision - Labor & Employment Insights, Issue 3, October 2023

New Business Reporting Obligations for Employers: Beneficial Ownership Information Under the Corporate Transparency Act - Effective January 1, 2024, most legal entities incorporated, organized, or registered to do business...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - September 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Walkers

AML update: regulatory expectations in respect of beneficial ownership & control

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The Jersey Financial Services Commission (the "JFSC") recently published feedback from its 2022 thematic examination on the extent to which supervised persons complied with their regulatory obligations with respect to...more

K2 Integrity

SEC Division of Examination Risk Alert Highlights Deficiencies in Broker-Dealers’ AML Compliance Programs

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The U.S. Securities and Exchange Commission (SEC) is responsible for protecting investors and ensuring the integrity of the securities markets. As part of this mission, the SEC requires broker-dealers to comply with...more

Proskauer - California Employment Law

Put it in Writing: Los Angeles Imposes New Requirements on Employers of Independent Contractors

As readers may know, the Los Angeles Freelance Worker Protections Ordinance took effect on July 1, 2023. The new law imposes additional requirements on businesses in the City of Los Angeles who have contracts with freelance...more

Brooks Pierce

[Webinar] AI Usage in the Workplace and the Employment Implications of the Corporate Transparency Act (CTA) - July 20th, 10:00 am...

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Brooks Pierce attorneys Beth Langley, Kemper Patton and Mark Davidson will present a labor and employment webinar on July 20 titled, “AI Usage in the Workplace and the Employment Implications of the Corporate Transparency...more

Conyers

Review & Reset: Topical Items for Consideration by Insurers

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It’s necessary from time to time to take a step back to review an insurer’s broader legal, regulatory and compliance landscape and reset and restructure its compliance procedures where required. We briefly set out below a...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

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In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Katten Muchin Rosenman LLP

Businesses Must Prepare For Expansive AML Reporting of Beneficial Ownership Interests

As covered in our earlier advisory, "AML Enforcement Continues to Trend in 2021," the recently passed National Defense Authorization Act for fiscal year 2021 included the Anti-Money Laundering Act of 2020 (AML Act), which...more

Foodman CPAs & Advisors

The BSA Casts A Wider Net

On  September 15, 2020,  FinCEN issued a Final Rule stating that Banks lacking a Federal Functional Regulator will be required to establish and implement AML programs including policies and procedures,  a dedicated compliance...more

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