Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network...more
In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more
5/20/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
Customer Identification Program (CIP) ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Investment Adviser ,
NPRM ,
Popular ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
In its latest attempt, the U.S. Department of Treasury, Financial Crimes Enforcement Network (“FinCEN”), will require certain investment advisers to implement compliance measures to detect and report suspected money...more
A broad array of financial market participants—mutual funds, private funds, insurers, pension funds, family offices, individuals, and more—may be at risk after the Securities and Exchange Commission (SEC) secured summary...more
On May 15, 2023, 22 state attorneys general sent a letter to several insurance companies warning that the companies’ Environmental, Social, and Governance (ESG) policies may violate the antitrust laws. Just six weeks earlier,...more