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Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Three Banks Targeted by FinCEN in FEND Off Fentanyl Act Actions: What to Know

On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more

FinCEN’s Weekend Present: No More CTA for U.S. Companies

As discussed in our March 4 Client Alert, following its February 27 and March 2 announcements suspending enforcement of the Corporate Transparency Act (CTA) and promising additional CTA compliance guidance, on the evening of...more

Lump of Coal in the CTA Stocking: Texas Federal Court of Appeals Stays Injunction Against Corporate Transparency Act

The U.S. Court of Appeals for the Fifth Circuit has granted the government’s motion to stay the Eastern District of Texas’ December 3 nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act...more

The Real (Estate) Deal: FinCEN’s New Reporting Requirements for Property Transfers

In response to illicit finance risks identified in the U.S. residential real estate sector, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced the issuance of its long-anticipated...more

Investment Advisers Prepare: The BSA is Here

On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more

Data Protection Demands Complicate CTA Compliance

On Jan. 1, the Corporate Transparency Act (CTA) went into effect, premised on the belief that illicit actors use corporate structures like shell companies and fronts to hide their identities and launder criminal proceeds...more

U.S. Treasury Issues Notice of Anti-Money Laundering Regulations for Residential Real Estate Transfers

On Feb. 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM)1 in response to illicit finance risks identified in the U.S. residential real estate...more

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

About Time: FinCEN Extends Deadline for New Companies Reporting Beneficial Ownership Information

On November 29, 2023, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (RIN 1506-AB62)1, extending the deadline for companies created or registered in 2024 to file beneficial owner...more

AML Best Practices for Private Funds: Red Flags and Responses for Private Funds

U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds)2 and their U.S. general partners, sponsors, and managers (Advisers) are not directly subject to the Bank Secrecy Act of 1970...more

SDNY U.S. Attorney's Office Charges First-Ever Digital Asset Insider Trading Scheme

Reaffirming DOJ’s focus on digital assets, the U.S. Attorney’s Office for the Southern District of New York today charged a defendant, for the first time ever, with insider trading in non-fungible tokens (NFTs). ...more

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