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Securities and Exchange Commission (SEC) Anti-Money Laundering National Security

Paul Hastings LLP

The Bybit Hack of 2025 — Potential Implications

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On February 21, 2025, Dubai-based Bybit, one of the world’s leading cryptocurrency exchanges, suffered a massive security breach, resulting in the loss of approximately $1.5 billion in Ethereum (ETH). The incident, which is...more

DLA Piper

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

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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

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

DLA Piper

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

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Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

K2 Integrity

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

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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

Jenner & Block

Client Alert: Unfinished Business: Investment Advisers Are Potentially Back on the Hook for Anti-Money-Laundering and...

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In its latest attempt, the U.S. Department of Treasury, Financial Crimes Enforcement Network (“FinCEN”), will require certain investment advisers to implement compliance measures to detect and report suspected money...more

White & Case LLP

FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs

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On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more

Proskauer Rose LLP

Wealth Management Update - December 2023

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Shining a Light on the Corporate Transparency Act: FinCEN’s Rules for Beneficial Ownership Reporting - On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering...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

Kohrman Jackson & Krantz LLP

SEC Efforts to Modernize Beneficial Ownership Reporting Don’t Go Far Enough

OVERLAP IN THE SECURITIES ACT OF 1934 - The Securities and Exchange Commission (SEC) presides over two separate beneficial ownership reporting schemes under Sections 13 and 16 of the Securities Exchange Act of 1934....more

Miller Canfield

FinCEN Publishes Notice of Proposed Rulemaking on the Corporate Transparency Act

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On December 8, 2021, the U.S. Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) implementing Section 6403 of the Corporate Transparency Act (CTA), which gives the public until...more

Bracewell LLP

Government Enforcement and Investigations Year-In-Review: The Administration Has Moved Its Pieces into Place

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On Monday, President Biden released the United States Strategy on Countering Corruption, which details how the United States will work “domestically and internationally, with governmental and non-governmental partners, to...more

Bracewell LLP

Biden Administration Prioritizes Increased and Broadened Anti-Corruption Enforcement

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On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity,...more

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