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The European Banking Authority consultation on customer due diligence under the EU’s 6th money laundering package closes on 06 June, 2025, with the EBA due to submit its findings to the European Commission’s call for evidence...more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more
Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly...more
The Financial Crimes Enforcement Network (“FinCEN”) recently advised that a financial institution is not required to file a Suspicious Activity Report (“SAR”) based solely upon a customer’s inquiry into or participation in a...more
It’s not just your taxes that are due each year on April 15. For financial institutions, this coming April 15 is the date the New York Department of Financial Services’ (NYDFS’s ) new Anti-Money Laundering (AML) Part 504...more
Second of a Two-Part Blog: Anti-Money Laundering Programs Coming to the Legal Profession? Earlier this week, we began our discussion of the proposed Corporate Transparency Act of 2017 (the “Act”), and observed that, if...more
On April 25, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, proposed a rule that would require all banks, regardless of whether they are subject to regulation by a...more
The Financial Crimes Enforcement Network (FinCEN) on Aug. 25, 2016, issued a notice of proposed rulemaking (Proposed Rule) to implement Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools...more
Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more
On December 2, the Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and...more