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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

SEC Adopts Long-Awaited and Heavily Debated Private Fund Adviser Rules

The U.S. Securities and Exchange Commission ("SEC") adopted multiple rules that will impact private funds, governing documents, and side letters....more

Japan's Financial Services Agency to Introduce New Exemption for Foreign Fund Managers

The Working Group Committee of Japan's Financial Services Agency has recommended a new exemption system for fund managers who manage overseas investors' funds, with fewer restrictions on eligible investors. On December 23,...more

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