News & Analysis as of July 30, 2025

Regulatory Requirements

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

FinCEN Postpones New AML Rule for Investment Advisers

Latham & Watkins LLP on 7/25/2025

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

FinCEN to Postpone Investment Adviser Anti-Money Laundering Rule

Cooley LLP on 7/23/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to (1) postpone until January 1, 2028, the effective date of the final anti-money laundering rule...more

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on 7/23/2025

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

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

Lowenstein Sandler LLP on 6/24/2025

On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more

Crypto Brief - Lowenstein Crypto Newsletter - May 29, 2025

Lowenstein Sandler LLP on 5/30/2025

On May 27, Circle Internet Group Inc., the issuer of the USDC stablecoin, announced its plan to go public via an initial public offering (IPO) on the New York Stock Exchange (NYSE). According to Circle’s Form S-1, Circle will...more

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

Gordon Rees Scully Mansukhani on 5/22/2025

The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more

Crypto Business Compliance: U.S. Licensing and Regulations

Carlton Fields on 3/4/2025

The crypto industry is evolving rapidly, and regulatory enforcement is keeping pace. Businesses engaged in crypto transactions, custody, lending, trading, or payments must navigate know your customer (KYC) and anti-money...more

Trump Administration’s Early Actions on Digital Assets

Brownstein Hyatt Farber Schreck on 2/5/2025

In the early days of the second Trump administration, the federal government has signaled a full-scale change in approach to digital assets. Gary Gensler is no longer the chairman of the Securities and Exchange Commission...more

SEC Charges Investment Adviser - Signaling Importance of Accurate Disclosure of AML Procedures

White & Case LLP on 1/29/2025

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

Dual Registrant Regulatory Roundup - January 2025

Eversheds Sutherland (US) LLP on 1/13/2025

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

The Corporate Transparency Act: A Reminder for Public Companies and Banks

Wyrick Robbins Yates & Ponton LLP on 11/18/2024

On January 1, 2025, business entities in existence prior to January 1, 2024 must file initial beneficial ownership reports with the Financial Crimes Enforcement Network (“FinCEN”) under the federal Corporate Transparency Act....more

Regulatory Roundup for September 2024

SEC Compliance Consultants, Inc. (SEC³) on 10/1/2024

Advisers Drafted by FinCEN for AML Duty, More Fines for E-Comm Retention Failures and a September Miracle, SEC Falls Back on Broken Windows Strategy, and a Refusal to Give Up on Private Fund Rules - FinCEN added to advisers’...more

Shifting Sands: The Future of Offshore Regulatory Disputes (Part 1)

Conyers on 9/6/2024

As an evolving area of commercial disputes in the Cayman Islands, global enforcement trends provide us with valuable insight into the types of regulatory proceedings on the horizon for offshore jurisdictions. In this first...more

Blockchain and Digital Assets News and Trends - August 2024

DLA Piper on 9/3/2024

This monthly bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

Skadden, Arps, Slate, Meagher & Flom LLP on 8/6/2024

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

Skadden, Arps, Slate, Meagher & Flom LLP on 5/30/2024

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

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

White & Case LLP on 5/21/2024

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

Reporting Requirements under the Corporate Transparency Act

Jenner & Block on 5/17/2024

The Financial Crimes Enforcement Network of the Department of the Treasury (FinCEN) issued final regulations under the Corporate Transparency Act (CTA) which, effective January 1, 2024, require most companies (i.e.,...more

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on 2/23/2024

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

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

Sheppard Mullin Richter & Hampton LLP on 2/19/2024

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

Who Must Be Reported as Beneficial Owners of a Reporting Company?

Verrill on 11/30/2023

In 2024 the Corporate Transparency Act (CTA) and related CTA Rule will require more than 30 million “Reporting Companies” to register with FinCEN, a bureau of U.S. Treasury. Registration occurs through online filings of...more

Private Clients Group Client Alert

Verrill on 11/22/2023

There have been a few important law and tax changes over the course of 2023 and we in the Private Clients Group here at Verrill wanted to make you aware of the recent changes, such as 1) new strict corporate reporting...more

The Federal Corporate Transparency Act Through the Lens of Private Equity: Unique Challenges Await

Bass, Berry & Sims PLC on 10/25/2023

With a stated goal of enhancing transparency of business ownership, the federal Corporate Transparency Act (CTA) mandates various types of businesses – such as corporations, limited liability companies, and limited...more

[Event] 2nd Forum on Digital Assets Compliance: AML, Sanctions and Regulatory Oversight - October 17th - 18th, New York, NY

American Conference Institute (ACI) on 9/25/2023

With so many new, emerging risks coming to the forefront, ACI is excited to announce our Digital Assets Compliance: AML, Sanctions and Regulatory Oversight. Unlike other conferences, this highly anticipated event stands apart...more

DeFi protocol Uniswap and investors avoid suit for fraudulent activity on digital asset exchange

A&O Shearman on 9/15/2023

On August 30, 2023, in a case of first impression, the U.S. District Court for the Southern District of New York dismissed in full a putative securities class action against Uniswap Labs, a decentralized finance (“DeFi”)...more

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