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
This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more
The incoming Trump administration will bring significant changes to regulatory policy as it relates to the asset management industry, and private funds, in particular...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
En el marco de la constante evolución del ecosistema financiero global y de la transformación digital que vivimos, la industria de los activos digitales sigue cobrando una gran relevancia, permitiendo redefinir las fronteras...more
FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more
1. Specific Financial Asset Types - 1.1 Common Financial Assets - A wide range of asset classes have been securitised by Irish special purpose entities (SPEs): residential mortgages; commercial mortgages; auto loans;...more
Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more
As the EU removes the Cayman Islands from the EU AML/CFT blacklist with effect from 7 February 2024, concerns and barriers for EU sell- and buy-side parties on securitisations involving Cayman SSPEs fall away....more
El 8/9/23, FinCEN emitió una alerta sobre una estafa frecuente de inversión en moneda virtual comúnmente conocida como ““masacre de cerdos” ” o “Pig Butchering”. La alerta de FinCEN sobre la “masacre de cerdos” aborda las...more
Hong Kong regulators recently brought criminal enforcement actions against virtual asset trading platform JPEX and individuals associated with the platform. This case has become the first opportunity for local authorities to...more
On 9/8/23, FinCEN issued an alert on a prevalent Virtual Currency Investment Scam commonly known as “Pig Butchering”. FinCEN’s Pig Butchering alert addresses “Pig butchering” scams which resemble the practice of fattening a...more
The U.S. Securities and Exchange Commission (SEC) is responsible for protecting investors and ensuring the integrity of the securities markets. As part of this mission, the SEC requires broker-dealers to comply with...more
Limited Liability Companies (“LLC”) are a familiar structuring tool for US managers and investors, and the introduction of the Jersey LLC is part of a strategy by the jurisdiction to increase its appeal to the US market. ...more
In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more
We previously have observed that financial institutions face an increasing risk that alleged Anti-Money Laundering (“AML”) and Counter-Terrorism Financing (“CTF”) violations will lead to follow-on allegations of securities...more