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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

Orrick, Herrington & Sutcliffe LLP

Arizona enacts law regulating crypto asset kiosk operators

On May 12, the Arizona Legislature enacted HB 2387 which creates new fraud prevention requirements for cryptocurrency kiosk operators doing business in the state. The law requires cryptocurrency kiosk operators to, among...more

Akerman LLP

Bringing Money Into the U.S.: Declare It or Risk Serious Consequences

Akerman LLP on

Bringing money, whether cash or other forms, into or out of the United States is generally legal, no matter the amount. However, the U.S. government requires you to report large sums....more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: Leaving on a (Qatari) Jet Plane

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some...more

Morrison & Foerster LLP

CFTC Advisory Outlines Materiality Criteria for Enforcement Referrals

On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...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

Greenberg Glusker LLP

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

Greenberg Glusker LLP on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

Epstein Becker & Green

CTA Interim Final Rule Eliminates Requirements for U.S. Companies and U.S. Individuals to File Beneficial Ownership Reports

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN), in an action that was promised earlier in March, issued an interim final rule (the “Interim Rule”) that removes all requirements for U.S. companies and...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

Vicente LLP

Corporate Transparency Act, We Hardly Knew Ye: What the Interim Final Rule Means for U.S. Businesses

Vicente LLP on

The Corporate Transparency Act (CTA) has undergone a significant shift. The FinCEN recently issued a new Interim Final Rule (IFR), dramatically narrowing the law's reach. As a result, most U.S. companies no longer have...more

A&O Shearman

UK FCA Primary Market Bulletin 54

A&O Shearman on

The Financial Conduct Authority (FCA) has published its Primary Market Bulletin 54 in which it discusses strategic leaks and unlawful disclosure. The FCA reports that it has seen an increase in instances where material...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

Kelley Drye & Warren LLP

Ad Law News and Views - January/February 2025

If you have been following our blogs, it should be no surprise that the Attorneys General remain focused on combatting Organized Retail Crime (ORC) using available state and federal tools. The Attorneys General of...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

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for December 2024

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: •Insider trading charges against a professor overseeing...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

Goodwin

Horizon Scan for Private Investment Funds - Autumn 2024

Goodwin on

Welcome to the third edition of our Horizon Scan for 2024: key recent and expected funds, regulatory and tax developments to look out for. As before, we focus on the most important developments and changes that we expect...more

Walkers

Channel Islands Regulatory Update: October 2024

Walkers on

The financial services sector in the Channel Islands has seen the publication of a report by MONEYVAL, a proposal to increase administrative penalties and the release of two public statements. The Bailiwick gambling...more

McCarter & English Blog: Government Contracts...

A New Frontier in Corporate Accountability: The DOJ’s Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice (DOJ) Criminal Division introduced its Corporate Whistleblower Awards Pilot Program (Program), which, like a modern-day Western posse, aims to bring justice to the wild frontier...more

Charles E. Rounds, Jr. - Suffolk University...

The federal Corporate Transparency Act (CTA), whose constitutionality is currently being tested in the courts, creates another...

The federal Corporate Transparency Act (CTA), effective January 1, 2024, whose constitutionality is currently being tested in the courts, follows in the footsteps of the IRC in that it creates a limited statutory exception...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

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