News & Analysis as of

Enforcement Actions Disclosure Requirements Anti-Money Laundering

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

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

SEC Compliance Consultants, Inc. (SEC³)

Predictions for 2025: What Private Fund Advisers Can Expect from SEC Examinations

There has been a lot of conjecture that the SEC may become friendlier to registrants because of the new administration. Given the SEC’s mandate to protect the investing public, however, we do not expect SEC examiners to...more

Ballard Spahr LLP

Treasury Announces Halt to CTA Enforcement—But Not Deadlines—for U.S. Citizens and Domestic Reporting Companies

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On March 2, 2025, the U.S. Department of Treasury announced that it will suspend enforcement of penalties and fines related to beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA) for...more

Butler Snow LLP

Treasury Department Limits Enforcement of the Corporate Transparency Act

Butler Snow LLP on

The Treasury Department announced on March 2nd that it does not intend to enforce any penalties or fines against either U.S. citizens or domestic reporting companies and their beneficial owners under the Corporate...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

Winthrop & Weinstine, P.A.

Client Alert: Corporate Transparency Act (CTA) Reporting Requirements Update

The Financial Crimes Enforcement Network (FinCEN) has reinstated the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA).  Following recent court decisions, the deadline...more

Greenberg Glusker LLP

Corporate Transparency Act Back in Effect: Updated BOI Compliance Deadlines

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UPDATE as of 2/20/25: The on-again, off-again Corporate Transparency Act (the “CTA”) mandatory beneficial ownership reporting is now back in effect. On February 18, 2025, the Texas federal district court in Smith v. United...more

Kerr Russell

The Corporate Transparency’s Act’s Impact on Medical Practices: Understanding Physicians’ Obligations Amid Recent Judicial and...

Kerr Russell on

Medical practices across the United States are grappling with new compliance obligations under the Corporate Transparency Act (CTA). This article addresses the CTA’s applicability to medical practices, its current legal...more

Flaster Greenberg PC

Corporate Transparency Act Updates

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(2/6/25) Update as of February 5, 2025: The government appealed the nationwide injunction blocking CTA enforcement in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). FinCEN updated its...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

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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

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

Foley Hoag LLP - White Collar Law &...

A Preview of SEC, CFTC, AML, Sanctions and CFIUS Enforcement Priorities Under the Second Trump Administration

As the incoming Trump administration prepares to take office, businesses and investors can expect significant shifts in the enforcement priorities of the Securities and Exchange Commission (SEC) and the Commodity Futures...more

Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

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Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Morrison & Foerster LLP

Top 5 SEC Developments for July 2023

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for December 2022

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important and interesting SEC enforcement developments from the past month, with links to primary...more

Perkins Coie

The Anti-Money Laundering Act of 2020: A Survey of Key Provisions and Practice Takeaways

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On New Year’s Day 2021, Congress overrode a presidential veto to pass the Anti-Money Laundering Act of 2020 (AMLA 2020), which amends and modernizes the Bank Secrecy Act (BSA). The AMLA 2020 includes sweeping reforms updating...more

Snell & Wilmer

New Year, New Laws – Congress Passes Major Anti-Money Laundering Act

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On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more

Skadden, Arps, Slate, Meagher & Flom LLP

Compliance in a Time of Crisis

Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more

Katten Muchin Rosenman LLP

Bridging the Weeks - July 2019 #4

The Commodity Futures Trading Commission and the Securities and Exchange Commission brought separate enforcement actions against the portfolio manager of a hedge fund for mismarking valuations of interest rate swaps in order...more

Akin Gump Strauss Hauer & Feld LLP

Developments in Cryptocurrency in 2018

• The U.S. Securities and Exchange Commission (SEC) staff made official statements regarding when a token may or may no longer be a security • The SEC continued to bring actions related to cryptocurrency offerings against...more

Blank Rome LLP

Regulatory Update and Recent SEC Enforcement Actions

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REGULATORY UPDATES - U.S. Securities and Exchange Commission (“SEC”) Offers Responses to Frequently Asked Questions on New Liquidity Rule - On January 10, 2018, the Division of Investment Management issued responses to a...more

Akin Gump Strauss Hauer & Feld LLP

In Principle: 10 Things Authorised Firms Need to Know for 2018 – The World of Financial Regulation as the UK Prepares to Exit the...

There is much for authorised firms to consider in the year ahead. Firms have been through the intensive period of the enactment of the second Markets in Financial Instruments Directive (MiFID II), but must now step up their...more

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