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Securities and Exchange Commission (SEC) Recordkeeping Requirements FinCEN

Lowenstein Sandler LLP

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

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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

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Neal, Gerber & Eisenberg LLP

New FinCEN Rule Imposes AML Requirements on Investment Advisers

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that will define most SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) as...more

Seward & Kissel LLP

Department of the Treasury Releases New AML/CFT Rule for Investment Advisers

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Who may be interested: Investment Advisers - Quick Take: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule subjecting certain registered investment advisers (RIAs) and...more

Seward & Kissel LLP

Q&A on FinCEN’s New AML Requirements for Certain Investment Advisers

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more

Lowenstein Sandler LLP

Investment Advisers Prepare: The BSA is Here

On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

Mayer Brown Free Writings + Perspectives

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more

King & Spalding

Request for Comments on FinCEN and SEC rule on CIP

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The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - May 2024

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

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

ArentFox Schiff on

On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

Goodwin

FinCEN Finalizes Rule Implementing beneficial Ownership Reporting Requirements Under the CTA

Goodwin on

Regulatory Developments - FinCEN Finalizes Rule Implementing Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act - On September 29, FinCEN issued a final rule under the CTA requiring each...more

Goodwin

Agencies Launch Digital Identity Tech Sprint

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

Goodwin on

In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Perkins Coie

Blockchain Week in Review - December 2020 #3

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CFTC Releases Digital Asset Primer - On December 17, 2020, the CFTC announced a 36-slide Digital Assets Primer. The Digital Assets Primer seeks to build on a prior 2017 release that focused on virtual currencies. This...more

Goodwin

OCC Finalizes “True Lender” Rule

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

Blank Rome LLP

Regulatory Update and Recent SEC Enforcement Actions

Blank Rome LLP on

On June 2, 2016, the SEC announced that it hired Christopher R. Hetner, a cybersecurity expert, as the Senior Adviser to the Chair for Cybersecurity Policy. The hire is indicative of the SEC’s focus on cybersecurity measures...more

Ballard Spahr LLP

Recent Investment Management Developments - May 2016

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Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. ...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Ballard Spahr LLP

Investment Management Update - October 2015

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Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

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On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

Foley Hoag LLP

FinCEN Proposed AML Rule For Investment Advisers

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The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more

Proskauer - Corporate Defense and Disputes

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

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