News & Analysis as of

Reporting Requirements AML/CFT

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

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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 postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

Seward & Kissel LLP

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

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On July 21, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was delaying the effective date of its final rule establishing Anti-Money Laundering/Countering the Financing...more

K&L Gates LLP

Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

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On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more

Morrison & Foerster LLP

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Ropes & Gray LLP

FinCEN Delays AML Program Rule for Investment Advisers

Ropes & Gray LLP on

On July 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it intends to delay implementation of its final rule, Anti-Money Laundering/Countering the Financing of Terrorism...more

K&L Gates LLP

Key Lessons From the Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

K&L Gates LLP on

On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) published a threat assessment (the Assessment) on compliance with UK sanctions and money laundering law for art market participants (AMPs) and high...more

Dorsey & Whitney LLP

Investment Adviser Compliance with FinCEN’s AML/CFT Rule

Dorsey & Whitney LLP on

On August 28, 2024, Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) that imposes comprehensive anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements on...more

A&O Shearman

FATF report identifies vulnerabilities in counter proliferation financing

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The Financial Action Task Force (FATF) has published a report and accompanying press release, highlighting significant vulnerabilities in the global financial system's ability to combat proliferation financing (PF) and...more

Lowenstein Sandler LLP

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

Lowenstein Sandler LLP on

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

Herbert Smith Freehills Kramer

AML/CTF reforms: Rules take shape with further Consultation

A quick recap on reforms affecting reporting entities The Amended AML/CTF Act removed the concept of "designated business groups" and replaced this with "reporting group". The concept of "reporting group" means that, if...more

Procopio, Cory, Hargreaves & Savitch LLP

Understanding FinCEN’s New AML/CFT Rule for Investment Advisers

What You Need to Know Before January 1, 2026 - Certain registered investment advisers (RIAs) and Exempt Reporting Advisors (ERAs) will face new federal compliance and filing requirements in the new year. Starting January 1,...more

A&O Shearman

UK Conduct Authority publishes report on assessing and reducing the risk of Money Laundering Through the Markets

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The Financial Conduct Authority has published a report on assessing and reducing the risk of Money Laundering Through the Markets. Money Laundering Through the Markets is the use of capital markets to launder criminally...more

K2 Integrity

Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now?

K2 Integrity on

On 15 January 2025, K2 Integrity hosted a webinar that featured Justina Rousseau, senior managing director at K2 Integrity; Aseel Rabie, counsel at Debevoise & Plimpton LLP; and Sarah Runge, executive managing director at K2...more

Conyers

Regulatory & Risk Advisory Outlook 2025: Cayman Islands

Conyers on

2024 was once again an active year for the Cayman Islands regulatory industry. In this edition of our Regulatory & Risk Advisory Outlook, our team has summarised the key changes and news during 2024 and taken a look at the...more

Carey Olsen

GLI British Virgin Islands blockchain and cryptocurrency regulation 2025, seventh edition

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Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more

Carey Olsen

A guide to blockchain and cryptocurrency regulation 2024: Cayman Islands (GLI chapter)

Carey Olsen on

Chris Duncan and Alistair Russell have authored the Cayman Islands chapter of Global Legal Insight's sixth edition guide to blockchain and cryptocurrency regulation. The chapter covers the Cayman legal requirements relating...more

Conyers

Regulatory & Risk Advisory Review: Cayman Islands – July to September 2024

Conyers on

Welcome to the third Regulatory & Risk Advisory Review instalment of 2024. In this edition we cover the latest Cayman Islands regulatory updates including the Beneficial Ownership Transparency Act and The Perpetuities...more

Walkers

Cayman Islands beneficial ownership regime: Update and progress towards 1 January 2025

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How does the beneficial ownership reporting regime developments impact those within the fund governance function? Introduction - As noted in our recent advisory, the Cayman Islands' beneficial ownership reporting...more

Cozen O'Connor

Corporate Transparency Act Compliance

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The federal Corporate Transparency Act (CTA) requires disclosure of information about all corporations, limited liability companies and limited partnerships (unless exempt), and personal information about their beneficial...more

Hahn Loeser & Parks LLP

90 Days and Counting for the Initial CTA Deadline

Time is running out. We are now in the 4th quarter of 2024 and despite legal challenges and proposed actions in the legislature, the year-end Corporate Transparency Act (“CTA”) reporting deadline remains incumbent upon...more

Walkers

Channel Islands Regulatory Update: October 2024

Walkers on

The financial services sector in the Channel Islands has seen the publication of a report by MONEYVAL, a proposal to increase administrative penalties and the release of two public statements. The Bailiwick gambling...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

A&O Shearman

UK Office of Financial Sanctions Implementation Annual Frozen Asset Review

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The Office of Financial Sanctions Implementation has published a financial sanctions notice reminding firms of their annual frozen assets reporting requirement. Every year HM Treasury carries out a review to update its...more

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

Foley Hoag LLP on

On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

Eversheds Sutherland (US) LLP

FinCEN adopts investment adviser AML rules

The Financial Crimes Enforcement Network (FinCEN) adopted a final rule that adds most federal Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to the definition of “financial institution” under the...more

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