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
On August 28, 2024, Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) that imposes comprehensive anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements on...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
Prior regulatory approval is now required for MLRO appointments – previously it was a notification requirement that had to be submitted within 14 days of the MLRO appointment. Firms in scope will now need to factor in...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
On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...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
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
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more
Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more
Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...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
The Jersey Financial Services Commission (the "JFSC") recently published feedback from its 2022 thematic examination on the extent to which supervised persons complied with their regulatory obligations with respect to...more
Following industry consultation, on 30 August 2023 the Cayman Islands Monetary Authority ("CIMA") issued updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation...more
Introduction - Further to a recent update, in which the Government, in consultation with the Jersey Financial Services Commission ("JFSC"), announced its intention to make legislative changes to the anti-money laundering,...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
On July 31, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMS) issued a risk alert summarizing observations from its recent anti-money laundering (AML) and counter-financing of terrorism...more
Both individuals and companies risk severe penalties if they contribute to money laundering, even if the contribution is the result of negligence. By appointing an anti-money laundering officer organisations will reduce their...more