News & Analysis as of

Anti-Money Laundering Disclosure Requirements Financial Crimes

Orrick, Herrington & Sutcliffe LLP

Rhode Island enacts new virtual currency kiosk provisions

On June 23, the governor of Rhode Island signed into law HB 5121 which grants Rhode Island new currency transmission laws to regulate and establish new licensing, disclosure and anti-fraud requirements for virtual currency...more

Proskauer - The Capital Commitment

Why the DOJ’s New Whistleblower Program Remains Relevant

On May 12, 2025, the U.S. Department of Justice (DOJ) issued a memorandum outlining the Criminal Division’s enforcement priorities and policies for prosecuting corporate and white-collar crimes in the new Administration....more

Orrick, Herrington & Sutcliffe LLP

Senators pen bipartisan letter arguing rescission of Treasury rule

On May 27, Sens. Sheldon Whitehouse (D-RI) and Charles Grassley (R-IA) wrote to the Treasury encouraging recission of the interim final rule requiring “foreign reporting companies,” but not domestic entities or U.S. citizens,...more

Conyers

Country Update - Bermuda: AML

Conyers on

Bermuda is a leading international financial centre and maintains a comprehensive body of primary legislation relating to money laundering and terrorist financing, supported by a range of general and sector specific guidance...more

WilmerHale

FCA's Regulatory Plans Signal Cause For Cautious Optimism

WilmerHale on

Supporting growth, fighting crime, helping consumers and being a smarter regulator: These are the four predictable priorities identified in the Financial Conduct Authority's 2025-2030 strategy document, released on March 25. ...more

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Interim Final Rule Under the Corporate Transparency Act

On March 21, 2025, FinCEN released an interim final rule (the “Interim Final Rule”) that exempts domestic reporting companies and U.S. persons from being required to report beneficial ownership and company applicant...more

White and Williams LLP

Latest Corporate Transparency Act Update from FinCEN: Enforcement Paused, For Now

Stay tuned – another shoe is likely to drop from Washington D.C. on the CTA (“Corporate Transparency Act”) in the next three weeks. As we previously reported on February 18, 2025, the U.S. District Court for the Eastern...more

White & Case LLP

SEC Charges Investment Adviser - Signaling Importance of Accurate Disclosure of AML Procedures

White & Case LLP on

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

ArentFox Schiff

SEC Charges Navy Capital in AML Failures: Say What You Do and Do What You Say

ArentFox Schiff on

The US Securities and Exchange Commission (SEC) released a press release on January 15 announcing that it had charged Navy Capital Green Management, LLC, an investment adviser, with violations of the Investment Advisers Act...more

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Ballard Spahr LLP

Treasury Issues Request for Information on Use of AI in Financial Services

Ballard Spahr LLP on

The U.S. Department of the Treasury (“Treasury”) has released a Request for Information on the Uses, Opportunities, and Risks of Artificial Intelligence (“AI”) in the Financial Services Sector (“RFI”).  Written comments are...more

Buchalter

Corporate Transparency Act Found Unconstitutional for Certain Businesses

Buchalter on

In March 2024, the Northern District of Alabama held that Congress exceeded its Constitutional authority by enacting the Corporate Transparency Act (“CTA”). The CTA requires variety corporate entities—everything from LLCs to...more

Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

Ballard Spahr LLP on

Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Venable LLP

Looming CTA Disclosure Requirements and Healthcare Providers

Venable LLP on

The Federal Corporate Transparency Act (the CTA), 31 U.S.C. §5336, will soon require certain entities to disclose to the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) certain pieces of identifying information...more

Benesch

Corporate Transparency Act Imposes New Federal Reporting Requirements on Small Businesses

Benesch on

With its effective date on the horizon, many businesses will now need to file reports with the U.S. Dept of Treasury FinCEN division under the new Corporate Transparency Act. This Act, which is part of Congress’ Anti-Money...more

Venable LLP

Navigating the Corporate Transparency Act

Venable LLP on

Federal law will soon require for the first time that certain companies disclose personally identifiable information about themselves and their beneficial owners and company applicants to U.S. Treasury’s Financial Crimes...more

Dorsey & Whitney LLP

The Economic Crime (Transparency and Enforcement) Act 2022: New Rules for Overseas Entities Owning Land in the UK

Dorsey & Whitney LLP on

The Economic Crime (Transparency and Enforcement) Act 2022 (“Act”) introduces new measures to tackle illicit wealth in the UK property market. The Act is comprised of three parts and Part 1 of the Act (“Part 1”), which became...more

Latham & Watkins LLP

New Disclosure Requirements Imposed on Overseas Entities Holding UK Property

Latham & Watkins LLP on

A new Register of Overseas Entities, expected this summer, requires disclosure of beneficial owners. The UK government has introduced legislation1 in Parliament to pave the way for the launch of the new Register of...more

A&O Shearman

Key Regulatory Topics: Weekly Update 26 Feb - 4 Mar 2021

A&O Shearman on

Brexit - FCA provides information on the Temporary Permissions Regime (TPR) On 3 March, the FCA published new webpages providing information on the TPR. Firstly, the FCA published a webpage on how it will supervise firms...more

Katten Muchin Rosenman LLP

Bridging the Weeks - July 2019 #4

The Commodity Futures Trading Commission and the Securities and Exchange Commission brought separate enforcement actions against the portfolio manager of a hedge fund for mismarking valuations of interest rate swaps in order...more

Stinson - Corporate & Securities Law Blog

FinCEN Seeks to Turn Beneficial Ownership Disclosure of Private Entities on its Head

My colleagues over at our banking blog have highlighted proposed regulations by the Financial Crimes Enforcement Network, or FinCEN, under the Bank Secrecy Act which are meant to combat illicit financial activity, including...more

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