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FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

SEC Exam Priorities Target AML

Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more

Review, then Reform? AMLA Charts a Path for the Future of SARs and CTRs

Eighth Blog Post in an Extended Series on Legislative Changes to the BSA/AML Regulatory Regime - As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) contains major changes to the Bank Secrecy Act (“BSA”),...more

Federal Reserve and FinCEN Raise Alarms Regarding Technology-Assisted Financial Fraud

The Federal Reserve and the Financial Crimes Enforcement Network, or FinCEN, both recently issued reports addressing worrisome trends in technology-assisted financial fraud.  The reports to engage the financial services...more

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