SEC Activity with Fixed Income and Credit Funds
Podcast - Developments in FDA & DOJ Regulation and Enforcement of Manufacturer Communications
Foreign device manufacturers should anticipate greater chance of FDA inspection under new FDA leadership
Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more
The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to...more
The Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) have recently stepped up the pressure on virtual currency companies. Increased regulatory scrutiny has largely taken the...more
The Financial Crimes Enforcement Network (FinCEN) and federal banking regulators recently issued a Joint Statement intended to clarify the due diligence obligations of banks under the Bank Secrecy Act (BSA) regarding...more
Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more
Earlier this month, senior officials of the global money laundering and terrorist financing watchdog—the Financial Action Task Force (FATF)—issued a paper identifying challenges, good practices, and policy responses to new...more
AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
Relief is Narrow, but FinCEN’s Explanation of Low Money Laundering Risk Posed by Lending Products is Instructive - On May 11, the Financial Crimes Enforcement Network (“FinCEN”) issued a ruling to provide exceptive relief...more
The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...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