Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) were less than six months away from the requirement to implement an anti-money laundering and countering the financing of terrorism (AML/CFT) program...more
As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more
9/24/2024
/ Civil Monetary Penalty ,
Cuban Assets Control Regulations (CACR) ,
Department of Labor (DOL) ,
Economic Sanctions ,
Enforcement ,
Interim Final Rules (IFR) ,
International Emergency Economic Powers Act (IEEPA) ,
Investigations ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Statute of Limitations ,
TWEA
Since January 1, 2024, when the Corporate Transparency Act’s (“CTA”) beneficial ownership reporting requirements became effective, a key issue has been whether companies that meet the requirements of a “reporting company” are...more
On September 15, 2020, the Conference of State Bank Supervisors (CSBS) announced a “one company, one exam” program for examinations of money services businesses. These businesses, spanning from money transmitters like PayPal...more
The Travel Rule is an old friend for those familiar with banking regulations and anti-money laundering rules. The Rule, first issued by FinCEN in 1995 with fiat currency in mind, requires banks and nonbank financial...more
10/2/2019
/ Anti-Money Laundering ,
Bitcoin ,
Cryptocurrency ,
Data Security ,
FATF ,
FinCEN ,
Money Services Business ,
New Guidance ,
Public Comment ,
Regulatory Requirements ,
Travel Rule ,
Virtual Currency