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Blockchain and Digital Assets News and Trends – March 2025

This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more

Recent Settlement Demonstrates DOJ’s Focus on Foreign Entities Misrepresenting Anti-Money Laundering Compliance

The US Department of Justice (DOJ) has announced that Wall Street Exchange (WSE), a Dubai-based money exchange service provider, entered into a non-prosecution agreement (NPA) and agreed to pay more than $9.2 million to...more

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

SEC Enforcement Actions Highlight Anti-Money Laundering Reporting Focus for Financial Gatekeepers

The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more

Treasury’s FinCEN and SEC Propose Rule Requiring Investment Advisers to Develop Customer Identification Programs

On May 13, 2024, the Securities and Exchange Commission (SEC) and the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly proposed a new rule that would impose requirements on SEC-registered...more

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