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U.S. Treasury Renews Push to Make Investment Advisers Subject to the BSA

The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more

Bipartisan Bill Seeks to Delay FinCEN’s Beneficial Ownership Reporting Requirements

On August 1, a bipartisan bill was introduced to modify the Corporate Transparency Act (CTA). The Protect Small Businesses and Prevent Illicit Financial Activity Act (H.R. 5119) was introduced in the U.S. House of...more

Startups: Beneficial Ownership Filings May Be Required After January 1, 2024

Founders and operators, is your company prepared to report its Beneficial Ownership Information (BOI)? Unless an exemption applies, you may be required under the Corporate Transparency Act (CTA) to identify and report the...more

Preparing Your Company for FinCEN’s Beneficial Ownership Reporting Requirements

On September 29, 2022, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements...more

AML Best Practices for Private Fund Managers: The Prudence of Establishing an AML Compliance Program

I. Introduction- U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds),1 and their U.S. general partners, sponsors, and managers (Advisers), are not directly subject to the...more

FinCEN Issues Historic Order Against Virtual Currency Exchange Facilitating Russian Illicit Finance

On January 18th, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first action (the Order) pursuant to Section 9714 of the Combating Russian Money Laundering Act1 to designate...more

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