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FinCEN Finalizes Rule Requiring AML/CFT Programs for Registered Investment Advisers and Exempt Reporting Advisers

On September 4, 2024, the U.S Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule that expands the definition of “financial institution” to include Registered Investment Advisers...more

Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions

Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more

Focus on Fintech – Q1 2024

In this latest edition, our attorneys discuss updates and developments from federal regulators, including those related to the intersection of fintech and artificial intelligence, cryptocurrency and virtual currency updates,...more

FinCEN Proposes Significant Expansion of AML/CFT Obligations to Cover Registered Investment Advisers, Venture Capital Advisers,...

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a sweeping expansion of the Bank Secrecy Act’s (BSA) affirmative anti-money laundering (AML) and countering the financing of...more

Focus on Fintech – Q4 2023

In this issue, we discuss updates and developments from federal regulators, including those related to the intersection of fintech and artificial intelligence, crypto-asset and central bank digital currencies, and consumer...more

Focus on Fintech – Q3 2023

In this most recent issue, we discuss a number of updates and developments from federal regulators, including those related to novel banking arrangements, misrepresentations in advertisements and marketing, the intersection...more

Focus on Fintech – Q2 2023

In this most recent issue, we discuss a number of federal banking agency updates, including the long-awaited Final Interagency Guidance on Third-Party Relationships and the Federal Reserve Bank of New York’s report on the...more

Considerations for M&A Transactions Involving Fintech Companies

M&A transactions involving financial services providers—including tech-based providers or “fintechs”—raise a host of unique questions based on the types of services they provide, which are often highly regulated and may...more

Focus on Fintech – Q1 2023

In this latest issue of the firm’s Focus on Fintech newsletter, our attorneys discuss the dissolution of Silicon Valley Bank and Signature Bank and the increased scrutiny on banking activity, as well as a number of updates...more

FinCEN Issues ‘First-of-its-Kind’ Order Against Crypto Asset Exchange Linked to Illicit Russian Activity

On January 18, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) designated Bitzlato Limited (Bitzlato), a crypto asset exchange business incorporated in Hong Kong, as a “primary money...more

Focus on Fintech – Q4 2022

In this latest issue of Wilson Sonsini's Focus on Fintech newsletter, we discuss the FTX bankruptcy and the increased federal regulatory scrutiny of crypto assets, and new rules and innovations in the payments...more

Focus on Fintech - Q3 2022

Welcome to Wilson Sonsini’s Focus on Fintech newsletter. This quarterly newsletter provides ongoing analysis and commentary on regulatory developments impacting the fintech industry. The third quarter of 2022 has been a...more

Cryptocurrency Exchange Platform Agrees to Pay over $53 Million for Anti-Money Laundering and Sanctions Violations

On October 11, 2022, the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced settlements with Bittrex Inc. (Bittrex). The settlements arise from violations of...more

Headed to the Metaverse? Be "The One" to Minimize Money Laundering Risk

Wilson Sonsini provides extensive and cutting-edge legal services for innovators, technology pioneers, and disruptors. As part of our focus on emerging technologies, our attorneys are publishing a series on applying and...more

No Foolish Transactions: A Few Guidelines for NFT Marketplace Participants to Mitigate Anti-Money Laundering Risks

The global NFT (non-fungible token) market now is worth dozens of billions of dollars annually. Innovators and early adopters, marketplaces, and sellers, are all eager to join this market but may have questions about how to...more

How Gaming Companies Can Become Inadvertent Money Services Businesses

Many federal anti-money laundering (AML) laws require proactive steps to guard against financial crime. While these laws requiring proactive measures generally apply only to financial institutions, gaming companies may...more

Anti-Money Laundering Obligations for Virtual Currency Companies

Virtual currency businesses are under scrutiny by U.S. anti-money laundering (AML) regulators. Earlier this year, U.S Treasury Secretary Steven Mnuchin emphasized that virtual currencies are subject to AML regulations. He...more

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