News & Analysis as of

Investment FinCEN

Haynes Boone

FinCEN Announces Intention to Postpone Effective Date of Anti-Money Laundering Rule for Registered Investment Advisers and Exempt...

Haynes Boone on

FinCEN will work through the rulemaking process to formally extend the IA AML Rule effective date and intends to provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective...more

Troutman Pepper Locke

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

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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

Cadwalader, Wickersham & Taft LLP

Operation and Structure of the GENIUS Act of 2025 on Payment Stablecoins

The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more

Cadwalader, Wickersham & Taft LLP

Rules in Motion, May 2025 - U.S. Issues Broad Sanctions Relief for Syria

On May 23, 2025, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25, which provides broad authorization for U.S. persons to engage in dealings prohibited under the Syrian Sanctions...more

DLA Piper

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

DLA Piper on

Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - December 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

DLA Piper

SEC Enforcement Actions Highlight Anti-Money Laundering Reporting Focus for Financial Gatekeepers

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The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more

Foodman CPAs & Advisors

FinCEN Final New Rules Close Loopholes in U.S. Financial System

On August 28, 2024, FinCEN Final New Rules were published that address vulnerabilities in the U.S. financial system and are part of an on going effort to combat illicit finance and protect U.S. national security, as well as...more

Foodman CPAs & Advisors

Pig Butchering Crypto Scams Rising

Pig Butchering Crypto Scams are scams which resemble the practice of fattening a hog before slaughter....more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

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Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Proskauer - The Capital Commitment

The Macro-Economic Environment: What It Means for VC Firms

Hope for a resurgence during 2024 in Venture Capital fundraising, investment, and returns was strong at the beginning of this year, with optimism fueled by the recovery in 2023 of U.S. stock markets (lead by the performance...more

Allen Barron, Inc.

When is a US Taxpayer Required to Disclose Offshore Accounts on an FBAR and Form 8938

Allen Barron, Inc. on

When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more

Partridge Snow & Hahn LLP

Recent Legal Developments Affecting Syndicated Real Estate Funds

Two recent developments may affect private funds, including syndicated real estate offerings.  First, at the end of last summer the SEC adopted the Private Fund Adviser rules, regulations that cover certain aspects of...more

Allen Barron, Inc.

What Happens If You Don't File an FBAR

Allen Barron, Inc. on

It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

K2 Integrity

Proposed Rule to Impose Anti-Money Laundering Requirements on Investment Advisers

K2 Integrity on

On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

Alston & Bird

Structured Finance Spectrum – Winter 2024

Alston & Bird on

Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the shifting single-family rental landscape, what’s next for EDGAR, and...more

Bass, Berry & Sims PLC

2024 Healthcare Private Equity Outlook & Trends

W ith various headwinds resulting in down volume in 2023, buyers and sellers alike find themselves asking whether 2024 will see a rebound in deal activity. As we begin 2024, we have highlighted the issues and trends that...more

K2 Integrity

The Challenge of Transparency in Preventing Financial Crime: Navigating Financial Integrity in a Changing Risk Landscape

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The landscape of financial crimes is constantly evolving, and the concept of transparency is being fundamentally challenged. A dynamic, innovative approach is imperative to preserve and shape the future of financial...more

Foodman CPAs & Advisors

Alerta De FinCEN De “Masacre De Cerdos”

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El 8/9/23, FinCEN emitió una alerta sobre una estafa frecuente de inversión en moneda virtual comúnmente conocida como ““masacre de cerdos” ” o “Pig Butchering”. La alerta de FinCEN sobre la “masacre de cerdos” aborda las...more

Foodman CPAs & Advisors

FinCEN’s Pig Butchering Alert

Foodman CPAs & Advisors on

On 9/8/23, FinCEN issued an alert on a prevalent Virtual Currency Investment Scam commonly known as “Pig Butchering”. FinCEN’s Pig Butchering alert addresses “Pig butchering” scams which resemble the practice of fattening a...more

Cadwalader, Wickersham & Taft LLP

Take Two: The Lummis-Gillibrand Crypto Assets Bill 2.0

On July 12, Senator Kirsten Gillibrand, a Democratic senator from New York who sits on the Senate Banking Committee, and Senator Cynthia Lummis, a Republican senator from Wyoming who sits on the Agriculture Committee, joined...more

Holland & Hart LLP

Continuing Reporting Obligations Under the Corporate Transparency Act: You're Never Done

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Most smaller businesses newly formed or registered to do business in the United States will soon be required to file their initial beneficial ownership report with the federal Financial Crimes Enforcement Network (FinCEN),...more

Proskauer Rose LLP

Shining a Light on the Corporate Transparency Act: FinCEN’s Rules for Beneficial Ownership Reporting

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On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 in the National Defense Authorization Act for Fiscal Year 2021. Congress passed the CTA to...more

Steptoe & Johnson PLLC

Corporate Transparency Act Update: Final Beneficial Owner Reporting Rule

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On December 1, 2021, we issued a client alert summarizing the Corporate Transparency Act (CTA), a federal law passed to fight “shell company” money laundering, tax fraud, and other financial crimes. The CTA provides for rules...more

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