On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date for certain investment advisers to implement anti-money...more
7/24/2025
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Investment Management ,
Regulatory Requirements ,
Rulemaking Process ,
Suspicious Activity Reports (SARs)
On September 20, 2023, the US Securities and Exchange Commission (SEC) voted by a 4-1 margin to adopt amendments to Rule 35d-1, commonly known as the “names rule” (Rule), under the Investment Company Act of 1940, as amended...more
In a Legal Alert issued before the SEC open meeting, we posed five questions that our Investment Services team would be looking out for as part of this meeting. We now have answers to some of these questions....more
7/31/2023
/ Analytics ,
Artificial Intelligence ,
Broker-Dealer ,
Compliance ,
Conflicts of Interest ,
Fiduciary Duty ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Proposed Rules ,
Regulation BI ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Standard of Care ,
Technology
Now that the dust has settled on the SEC’s enforcement action against fifteen (15) broker-dealers and an investment adviser for violations of SEC recordkeeping rules applicable to the use of personal devices and off-channel...more
The compliance date for two rules adopted by the US Securities and Exchange Commission (SEC) last year, Regulation Best Interest (Reg BI) and the Form CRS Relationship Summary (Form CRS) is rapidly approaching for...more
The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more
1/20/2020
/ Annual Reports ,
Anti-Money Laundering ,
Banks ,
BSA/AML ,
Chief Compliance Officers ,
Compliance ,
CSBS ,
Examination Priorities ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Interpretive Opinions ,
Joint Statements ,
OCC ,
Risk Assessment ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
Technology ,
Terrorism Funding
On December 23, 2013, the Securities and Exchange Commission (SEC) approved proposed changes to the Financial Industry Regulatory Authority’s (FINRA) supervision rules. On March 19, 2014, FINRA issued Regulatory Notice...more
On January 28, 2014, the U.S. Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert entitled: Investment Adviser Due Diligence Processes for Selecting...more
On January 9, 2014, the U.S. Securities and Exchange Commission (SEC) published its 2014 examination priorities letter (“SEC Letter”) for its National Examination Program (NEP). The NEP covers all markets and entities...more