News & Analysis as of

Comment Period AML/CFT

Troutman Pepper Locke

Treasury Issues Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets

Troutman Pepper Locke on

On August 18, the U.S. Department of the Treasury issued a Request for Comment, inviting interested members of the public to provide input on innovative methods to detect and mitigate illicit finance risks involving digital...more

Orrick, Herrington & Sutcliffe LLP

Treasury Initiates Action Under GENIUS Act, Issues RFC on Detecting Illicit Finance

On August 18, the U.S. Department of the Treasury issued a Request for Comment (RFC) in a direct step toward implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) and in support...more

A&O Shearman

Financial Action Taskforce Publishes Consultation on Changes to AML/CFT and Financial Inclusion Standards

A&O Shearman on

The Financial Action Taskforce has published a consultation paper on revisions to its anti-money laundering and counterterrorism financing standards relating to financial inclusion. The consultation is part of FATF's program...more

Vedder Price

SEC and FinCEN Propose Customer Identification Program Requirements for Investment Advisers

Vedder Price on

On May 13, 2024, the SEC and FinCEN jointly proposed a new rule under the Bank Secrecy Act (BSA) that would impose new customer identification program (CIP) requirements on registered investment advisers and exempt reporting...more

Herbert Smith Freehills Kramer

SEC and FinCEN Propose Rule Requiring Investment Advisers to Enact Customer Identification Programs

On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department announced a joint notice of proposed rulemaking that would require investment...more

BCLP

SEC and FinCEN Propose Rules to Impose Customer Identification Program Obligations on Certain Investment Advisers

BCLP on

On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Stinson LLP

SEC, FinCEN Propose Customer Identification Program Requirements for RIAs and ERAs

Stinson LLP on

On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking (proposed rule) that would impact how investment advisers handle...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on

On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Stark & Stark

Proposed AML Suspicious Activity Rule

Stark & Stark on

On February 13, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule to combat criminals and foreign adversaries from exploiting the U.S. financial system through investment...more

Troutman Pepper Locke

FinCEN Proposes Extending AML/CFT Requirements to Certain Investment Advisors

Troutman Pepper Locke on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently announced a Notice of Proposed Rulemaking (NPRM) aimed at keeping bad actors from exploiting the U.S. financial system and assets...more

Ballard Spahr LLP

FinCEN Seeks Comments on Modernizing the AML/CFT Regime

Ballard Spahr LLP on

On December 14, the Financial Crimes Enforcement Network (“FinCEN”) issued a request for information (“RFI”), seeking comment on ways to “streamline, modernize, and update” the anti-money laundering (“AML”) and...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

WilmerHale

‘Closing the door on dirty money’: the European Commission’s Anti–Money Laundering Action Plan

WilmerHale on

On 7 May 2020, the European Commission (Commission) issued a comprehensive and ambitious Action Plan and public consultation designed to strengthen the European Union's (EU) legal framework to fight against money laundering...more

A&O Shearman

UK Conduct Regulator Consults on Guidance on Managing Inside Information

A&O Shearman on

The U.K. Financial Conduct Authority has published a newsletter for primary market participants seeking feedback on draft best practice guidance for government departments, industry regulators and public bodies on the...more

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