On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued Interpretative Letter 1184 (“IL 1184”) confirming that national banks and federal savings associations may provide cryptocurrency custody...more
5/20/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Regulatory Reform ,
FinTech ,
New Guidance ,
OCC ,
Regulatory Authority ,
Regulatory Requirements ,
Trump Administration
On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more
On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more
I. INTRODUCTION -
On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more
5/31/2024
/ Anti-Money Laundering ,
Compliance ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
NPRM ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
On April 18, 2024, the Financial Crimes Enforcement Network (“FinCEN”) announced its revised implementation schedule for providing access to the beneficial ownership information (“BOI”) reports. The tentative, revised...more
On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more
On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more
2/16/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Popular ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On January 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (the “Department”) issued a notice of proposed rulemaking seeking comment on a proposed regulation in response to the Executive Order (E.O.)...more
2/15/2024
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Cloud Computing ,
Comment Period ,
Customer Identification Program (CIP) ,
Cybersecurity ,
Executive Orders ,
Financial Institutions ,
IaaS ,
Machine Learning ,
National Security ,
NPRM ,
Proposed Regulation ,
U.S. Commerce Department
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released a final rule to implement the beneficial ownership information (“BOI”) access requirements of the Corporate Transparency Act (“CTA”) (the...more
12/29/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Popular ,
Regulatory Requirements ,
Reporting Requirements