II-26 – Superbowl Concerns, Tax Reform/MeToo, Restrictive Covenant Crimes, and Expanded Religious Discrimination Theories
On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone, for two years, the effective date of a final rule subjecting investment advisers to the anti-money laundering (AML)...more
Yesterday, the New York City Department of Consumer and Worker Protection (NYC DCWP) announced another delay in the effective date of its amended debt collection rules. This marks the second postponement. As discussed here,...more
FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more
On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more
In January 2025, the New York City Department of Consumer and Worker Protection (DCWP) issued a Notice of Change of Effective Date (Notice), further delaying the effective date for the final rules relating to debt collectors...more