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Investment Adviser Regulatory Requirements Financial Institutions

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

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Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Delays Effective Date of Investment Adviser Rule and Intends to Revisit the SEC Customer Identification Program Rule for...

In September 2024, FinCEN issued the Investment Adviser Rule, which aims to “address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial...more

Eversheds Sutherland (US) LLP

Preparing for Regulation S-P and takeaways from the SEC’s session at the Incident Response Forum Masterclass 2025

On April 22, 2025, Laura D’Allaird, Chief of the SEC’s Cyber and Emerging Technologies Unit (CETU), participated in the Incident Response Forum Masterclass 2025 (Incident Response Masterclass). In the session, titled “SEC...more

A&O Shearman

FCA publishes consultation on streamlining data collection requirements

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The UK Financial Conduct Authority (FCA) has published a consultation paper (CP) proposing the removal of reporting and notification requirements as part of its strategy to prevent unnecessary collection of data to reduce...more

Faegre Drinker Biddle & Reath LLP

Things I Worry About (10): FINRA Enforcement and Senior Investors (2)

Key Takeaways - FINRA’s 2025 Annual Regulatory Oversight Report 2025-annual-regulatory-oversight-report.pdf included a focus on issues related to retirees and senior investors. - The Report provides guidance to...more

Walkers

Moving to the Channel Islands: A guide for asset managers

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Jersey and Guernsey have long been recognised as leading international investment hubs, offering asset managers a compelling mix of professional and lifestyle advantages....more

Morgan Lewis

Temporary Reprieve for New Short Sale Reporting on Form SHO; Filings not Due Until 2026

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The date for complying with new Rule 13f-2 and filing Form SHO has been extended by one year. The first filings by covered institutional investment managers will now be due February 17, 2026, rather than February 14, 2025....more

Jenner & Block

FinTech Focus: Investment Advisers Join Ranks of Financial Institutions Subject to the Bank Secrecy Act

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Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network...more

A&O Shearman

UK allows bundled payments for third-party research and trading commissions

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From 1 August 2024, the UK changed its rules on how payments are made for investment research. UK firms may now use bundled payments for third-party research and trading commissions, subject to certain requirements being...more

J.S. Held

Off-Channel Communications: How Financial Services Organizations Can Address Regulators’ Latest Target

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As a number of recent headlines demonstrate, the U.S. Securities and Exchange Commission (SEC) and other regulators have fined and penalized employers and employees in the financial services industry for non-compliance with...more

Goodwin

Supreme Court Decision Empowers President Biden to Replace Director of FHFA

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In This Issue. In a move that gives him the opportunity to put his stamp on housing policy and the potential overhaul of Fannie Mae and Freddie Mac, President Biden replaced the Director of the Federal Housing Finance Agency...more

Goodwin

Financial Services Weekly Roundup: Code Libor – SEC And OCIE Issue Risk Alert In Preparation Of Libor Discontinuation

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In This Issue. The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert about the scope and content of examinations OCIE plans to conduct of various...more

Eversheds Sutherland (US) LLP

Videocast: Asset management regulation in 2020 videocast series – Regulators step up pressure to implement LIBOR transition plans

Regulators are increasing pressure on financial institutions to demonstrate that they are proactively addressing the transition away from the London Interbank Offered Rate (LIBOR). The New York State Department of Financial...more

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