Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more
5/6/2025
/ China ,
Compliance ,
Data Security ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
Foreign Entities ,
International Data Transfers ,
National Security ,
Regulatory Requirements ,
Russia
On February 27, 2025, the Securities and Exchange Commission formally abandoned its enforcement action against Coinbase. ...more
3/5/2025
/ Coinbase ,
Compliance ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Financial Regulatory Reform ,
Howey ,
Investment ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
During the past 12-18 months, we have noted a significant increase in the number of brokers underwriting share certificates issued by credit unions. It is vital for brokers in the credit union share certificate market to...more
1/16/2025
/ Broker-Dealer ,
Compliance ,
Credit Unions ,
Deposit Insurance ,
Disclosure Requirements ,
Financial Institutions ,
Financial Services Industry ,
NCUA ,
Regulatory Requirements ,
Risk Management ,
State and Local Government
On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more
3/8/2024
/ AML/CFT ,
Closed-End Funds ,
Compliance ,
Customer Due Diligence (CDD) ,
Employee Training ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
FinCEN ,
Internal Controls ,
Mutual Funds ,
Notice of Proposed Rulemaking (NOPR) ,
Patriot Act ,
Policies and Procedures ,
Private Funds ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Reporting Requirements ,
Risk Assessment ,
Travel Rule
Last week, the SEC took dead aim at Coinbase. This week, the CFTC did the same to Binance and its ubiquitous boss popularly known as CZ.
On March 27, 2023, the Commodity Futures Trading Commission (“CFTC”) filed a civil...more
DOJ Promotes Compliance Through Compensation and Clawback Programs (3.2.2023):
• The DOJ announced corporate criminal resolutions will now include a requirement that companies implement a compensation and bonus scheme...more
3/10/2023
/ 10b5-1 Plans ,
Bank Fraud ,
CFTC ,
Clawbacks ,
Compensation ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
Insider Trading ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements
On July 8, 2022, the California Privacy Protection Agency (“CPPA”) published draft regulations in the California Regulatory Notice Register (“Draft Regulations”) mandated by the California Privacy Rights Act (“CPRA”). The...more