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Investment Advisers Subject to AML and SARs Requirements

The Situation: The Financial Crimes Enforcement Network ("FinCEN") has adopted a rule that subjects certain investment advisers to anti-money laundering/countering the financing of terrorism program ("AML") requirements...more

What About the Kitchen Sink? FSOC Plans Even More in 2024

In Short - The Situation: Over the course of 2023, the Financial Stability Oversight Council ("FSOC") took steps that increase the risk of nonbank financial companies and financial activities being designated as...more

FSOC Proposals Renew Threat of Nonbank "Systemically Important" Designations

In Short - The Situation: The Financial Stability Oversight Council ("FSOC") recently issued a "notification of proposed interpretive guidance" on updated procedures for designating nonbank financial companies as...more

2021 Transactional Year in Review and 2022 Forecast - The ESG Surge Continues: Focus on Europe

The focus on ESG across the business spectrum ramped up over the course of 2021, surpassing several milestones along the way and resulting in a surge of regulatory changes and new initiatives by the end of the year....more

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