Regulatory Ramblings: Episode 81 - The Compliance Implications of Chinese Wealth Flooding Singapore // Spotlight on: HK Regulators Moving Digital Assets Forward with Donald Day and Philippa Allen
Our initial spotlight segment begins with reference to a recent LinkedIn Post authored by Don, entitled Hong Kong Raises the Bar in Digital Finance. He praised the SFC and HKMA’s recent circular update on the territory’s...more
En mayo de 2025, Costa Rica reformó el Artículo 32 de su Constitución para permitir la extradición de ciudadanos costarricenses en casos de narcotráfico internacional y terrorismo. Este cambio histórico pone fin a una...more
In May 2025, Costa Rica amended Article 32 of its constitution to allow the extradition of Costa Rican nationals in cases of international drug trafficking and terrorism. For decades, nationals were constitutionally shielded...more
The UK Financial Conduct Authority (FCA) has issued finalised guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes. There is no significant shift in the FCA’s expectations of...more
July saw a number of updates regarding the prevention of money laundering in the UK, reflecting the Government’s stated commitment to ensuring that compliance requirements are effective yet not unnecessarily onerous for the...more
Por primera vez desde su promulgación en 2018, la Ley 27.401 de Argentina (Ley de Responsabilidad Penal Empresaria) ha sido aplicada en un caso que involucra a una sucursal local de una empresa de seguridad de capital...more
Chile’s Financial Analysis Unit (FAU) has published its Circular No. 62, also known as the Updated Compilation of Rules (RAN), which compiles, systematizes, and updates key requirements for all regulated entities that carry...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more
Regulator finds that firms could improve how they conduct anti-money laundering checks when dealing with UK PEPs. ...more
The Jersey Financial Services Commission ("JFSC") recently announced that its first area of focus for its 2024 thematic examination programme will be politically exposed persons ("PEPs") (the "Examination"). The Examination...more
The UK Financial Conduct Authority (FCA) launched in September a review of the treatment of domestic politically exposed persons (PEPs) by UK-regulated financial services firms. This review will look at firms’ arrangements...more
The Jersey Financial Services Commission ("JFSC") recently launched a consultation on further amendments to its anti-money laundering/countering the financing of terrorism/countering proliferation finance ("AML/CFT/CPF")...more
U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds)2 and their U.S. general partners, sponsors, and managers (Advisers) are not directly subject to the Bank Secrecy Act of 1970...more
On 25 May 2023, the FIU Regulation containing anomaly indicators to be used by obliged entities for suspicious transactions reporting was published in the Official Gazette....more
On January 4, 2023, the New York State Department of Financial Services (“NYDFS”) issued a consent order against Coinbase, Inc. (“Coinbase” or the “Company”), the largest U.S.-based cryptocurrency trading exchange, for...more
In the early hours of 15 March 2022, the Economic Crime (Transparency and Enforcement) Act (the “Act”) came into force. The rapid passage of the Act through the UK Parliament, after years of delays, came in response to...more
The UK sanctions imposed as a result of Russia’s invasion of Ukraine have undoubtedly put intense pressure on businesses to review existing commercial arrangements and tighten sanctions compliance systems and controls. But...more
The Treasury Department’s Office of Foreign Asset Control had another consistent year – not a big year but continued adherence to its enforcement program. At the end of the year, OFAC announced a settlement with TD Bank...more
On December 1, 2021, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the “Manual”), which provides guidance to...more
Introduction - The art market is characterised by high-value, portable items that can be bought and exchanged quickly and often confidentially. These features, which make the market inherently vulnerable to many types of...more
This week, the Securities and Exchange Commission (SEC) obtained a Final Judgment against Asante Berko, former employee of a Goldman Sachs subsidiary, for, as noted in the SEC Press Release, his role in orchestrating a...more
This week has seemingly turned into a series of blogs posts which are primers for areas which are still of concern under the Foreign Corrupt Practices Act (FCPA) and for compliance professionals. I previously looked at...more
The FCA is extending its existing annual financial crime reporting obligation (termed the “REP-CRIM” by the FCA) to a broader range of firm types. The change is expected to impact approximately 4500 firms who were previously...more
The U.S. Anti-Money Laundering Act of 2020 (AML Act) became law on January 1 when the United States Congress passed the broader National Defense Authorization Act for 2021 over a presidential veto. Although it is a U.S. law,...more
On January 1, 2021, the Senate voted to override the president’s veto and to enact the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA”). Incorporated into the NDAA, the Anti-Money Laundering Act (“AMLA”)...more