News & Analysis as of

Compliance Securities and Exchange Commission (SEC) U.S. Treasury

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

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On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Seward & Kissel LLP

SEC Extends Compliance Dates for UST Repo and Cash Transaction Clearing Rule

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On February 25, 2025, the SEC released a statement extending the compliance deadlines to clear US Treasury (“UST”) repo and cash transactions under the US Treasury Clearing Rule (“Clearing Rule”) by one-year. In the...more

Eversheds Sutherland (US) LLP

SEC approves extension of Treasury clearing compliance dates

On Tuesday, February 25, 2025, the Securities and Exchange Commission (SEC) issued a one-year extension of the compliance dates for its clearing mandate for certain US Treasury cash and repurchase (repo) transactions, in...more

Mayer Brown Free Writings + Perspectives

SEC Extends Compliance Dates and Provides Temporary Exemption for Rule Related to Clearing of U.S. Treasury Securities

On February 25, 2025, the SEC extended the compliance dates for Rule 17ad-22(e)(18)(iv)(A) and (B) under the Securities Exchange Act for eligible cash market transactions by one year to December 31, 2026, and for eligible...more

Paul Hastings LLP

Crypto Executive Order: A New Era for Digital Assets

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President Trump’s crypto executive order (the Crypto Executive Order) was a first step in the Trump Administration’s articulation of a policy on promoting the lawful use of blockchain technology. It remains to be seen whether...more

The Volkov Law Group

FCPA Predictions: Don’t Expect Much to Change

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In 2017, when President Trump first took office, big changes were expected in FCPA enforcement.  Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA.  He was not a big fan of the law and...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

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On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...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

Mintz Edge

New for 2024: Compliance with the Corporate Transparency Act Necessary for Many Mintz Client

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Clients with Limited Liability Companies, Corporations, and Other Entities Likely Impacted - Reporting requirements under the Corporate Transparency Act (CTA) are in effect beginning January 1, 2024. Under the CTA,...more

Sunstein LLP

Tango Your Way to Government Compliance: The Corporate Transparency Act

Sunstein LLP on

Why might a 255 foot yacht named “Tango” anchored in Mallorca make your life more complicated? Because its owner, Russian oligarch Viktor Vekselberg, had been sanctioned by the U.S. in 2018 for “contributing to the situation...more

Seward & Kissel LLP

SEC Approves Final Rule – Mandatory Clearing of Transactions in US Treasury Securities

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On December 13, 2023, the Securities and Exchange Commission (the “SEC”) voted 4-1, to adopt Standards for Covered Clearing Agencies for U.S. Treasury Securities and Application of the Broker-Dealer Customer Protection Rule...more

BakerHostetler

NFTs Used to Serve Complaint; Treasury Official, SEC Chairman Address Crypto Compliance; NYAG Sues Crypto Exchange; DOJ Takes Down...

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NFT Integration Software Released; NFTs Used to Serve Complaint in Civil Action - According to a recent press release, a major U.S. software company has launched a suite of tools that will allow users to “enter the Web3 and...more

Goodwin

FinCEN Finalizes Rule Implementing beneficial Ownership Reporting Requirements Under the CTA

Goodwin on

Regulatory Developments - FinCEN Finalizes Rule Implementing Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act - On September 29, FinCEN issued a final rule under the CTA requiring each...more

Goodwin

SEC Proposes Rules to Improve Risk Management in Clearance and Settlement and to Facilitate Additional Central Clearing for the...

Goodwin on

Regulatory Developments - SEC Proposes Rules to Improve Risk Management in Clearance and Settlement and to Facilitate Additional Central Clearing for the U.S. Treasury Market - On September 14, the SEC proposed rule...more

Eversheds Sutherland (US) LLP

Stablecoins: some key regulatory and enforcement initiatives of US regulators

During the past few months, the US Treasury, the US banking agencies, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have pursued several regulatory or enforcement initiatives...more

Miller Canfield

Biden Memorandum on Combating Corruption Likely Means Increased FCPA Enforcement

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Earlier this month, the Biden Administration formally announced that combating corruption is a core United States national security interest. On June 3, 2021, the Biden Administration issued a Memorandum on Establishing the...more

Lowenstein Sandler LLP

2020 and Q1 2021 Developments And Annual Compliance Checklists

Summaries of recent legislative and regulatory developments with respect to: •The SEC’s Examination Priorities for 2021- •The SEC’s Focus on Digital Asset Securities- •The SEC’s New Marketing Rule... ...more

Dorsey & Whitney LLP

The SEC and SARs

Dorsey & Whitney LLP on

The Commission periodically has filed enforcement actions against broker-dealers for failing to file SARs - suspicious activity reports - typically centered on a failure to file reports regarding microcap issuers. Those...more

Lowenstein Sandler LLP

The SEC Identifies Common Investment Adviser Compliance Program Deficiencies Consistent With Deficiencies Recognized By Other...

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On November 19, 2020, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert (the Risk Alert) identifying common compliance issues related to Rule 206(4)-7 (the...more

ArentFox Schiff

JPMorgan Chase DPA Provides Insight into Government’s Assessment of Compliance Programs

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On September 29, 2020, US authorities announced that they reached an agreement with JPMorgan Chase & Co. (JPMorgan Chase) to settle criminal charges related to two distinct years-long market manipulation schemes involving...more

Holland & Knight LLP

Treasury Releases 2020 National Strategy for Combating Terrorist and Other Illicit Financing

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The 2020 National Strategy for Combating Terrorist and Other Illicit Financing was issued earlier this month by the U.S. Department of the Treasury. Prepared in consultation with regulators and law enforcement, including the...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

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TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

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