Compliance Tip of the Day: Citibank and Continuous Monitoring
Business Better Podcast Episode: FinCEN’s Notice of Proposed Regulations to Strengthen and Modernize AML/CFT Compliance Programs
Crypto Year in Review 2022: Crypto Enforcement and the U.S. Treasury - The Crypto Exchange Podcast
After two rounds of consultation, the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (New AML Rules) were made on 29 August 2025 alongside the Anti-Money Laundering and Counter-Terroism Financing (Class...more
Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more
FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more
The evolving U.S.-Mexico geopolitical relationship is now fundamentally burdened by the growing regulatory, enforcement, and real risks tied to cartel activity, drug trafficking and the fentanyl trade, immigration, and a...more
On July 21, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was delaying the effective date of its final rule establishing Anti-Money Laundering/Countering the Financing...more
On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date for certain investment advisers to implement anti-money...more
Pending completion of its recommended actions under the BVI Mutual Evaluation Report published by the Caribbean FATF in February 2024, the BVI has been included on the FATF's list of "jurisdictions under increased...more
Welcome to the first 2025 edition of our Regulatory & Risk Advisory Review. In this instalment, we provide a comprehensive overview of the latest regulatory developments to ensure you have the most up-to-date insights into...more
The Financial Action Task Force (FATF) has published an updated version of its anti-money laundering (AML) and counter-terrorist financing (CTF) standards after the February FATF Plenary approved changes to Recommendation 1...more
The advent and rise of cryptocurrency have been a disruptor to the traditional currency system. Even outside the virtual aspect of the currency, the concept is novel due to its accessibility and the level of anonymity...more
As financial technologies companies expand operations across borders, understanding the sanctions regimes of both the United States and South Korea becomes essential. The U.S. Treasury Department’s Office of Foreign Assets...more
The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures. As we...more
The UAE has continued to implement significant legislative and structural reforms during 2024 in areas including financial crime compliance, whistleblowing, and virtual assets regulation. These improvements demonstrate the...more
On 13 December 2024, the Commission de Surveillance du Secteur Financier (CSSF) published the first FAQ to assist professionals in the investment sector supervised, authorised, or registered by the CSSF in complying with...more
Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more
On 10/10/24, FinCEN assessed a record $1.3 billion penalty against TD Bank for BSA violations. This unprecedented penalty should function as a cautionary message and a warning to all financial institutions. All financial...more
On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more
Conducting an independent AML audit at a frequency based on the nature, scale and complexity of the entity is a requirement under the AML Regulations. AML audits are an important component of the control environment to...more
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that will define most SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) as...more
How does the beneficial ownership reporting regime developments impact those within the fund governance function? Introduction - As noted in our recent advisory, the Cayman Islands' beneficial ownership reporting...more
The government of the British Virgin Islands (“BVI”) and the BVI Financial Services Commission (“FSC”) – the principal financial services regulator – have progressed important initiatives in recent years that demonstrate the...more
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more
Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more
On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more
On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule that will, upon effectiveness (January 1, 2026), require most private fund managers to...more