News & Analysis as of

Securities and Exchange Commission (SEC) Suspicious Activity Reports (SARs) Financial Services Industry

Gordon Rees Scully Mansukhani

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more

Stinson LLP

SEC, FinCEN Propose Customer Identification Program Requirements for RIAs and ERAs

Stinson LLP on

On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking (proposed rule) that would impact how investment advisers handle...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Troutman Pepper Locke

SEC’s 2024 Examination Priorities: Implications for Consumer Financial Services

Troutman Pepper Locke on

The Securities and Exchange Commission’s Division of Examinations has outlined its 2024 Examination Priorities, with a significant focus on cryptocurrency, emerging technology, and Anti-Money Laundering (AML) laws. This has...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2023

Troutman Pepper Locke on

To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more

Ballard Spahr LLP

SEC Issues Alert Outlining Deficiencies in Broker-Dealers’ AML Compliance

Ballard Spahr LLP on

On July 31, 2023, the United States Securities and Exchange Commission (“SEC”) published an alert outlining deficiencies the Department of Examinations has observed in broker-dealers’ (“BD”) compliance with anti-money...more

Bradley Arant Boult Cummings LLP

Subpoena Responses for Financial Institutions

Financial services companies, such as banks, credit unions, lenders, finance companies, loan servicers, broker-dealers, and securities firms, often receive subpoenas from parties in litigation involving their customers,...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Goodwin

FinCEN Proposes Rule for SARs Sharing Pilot Program

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Goodwin

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

Goodwin on

In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more

Mintz - Securities & Capital Markets...

Interactive Brokers LLC Submits to SEC, FINRA, and CFTC Penalties Totalling $38 Over Widespread AML Failures

Interactive Brokers LLC (“Interactive Brokers”) recently settled with three separate regulatory entities for a total of $38 million, without admitting or denying the findings. According to the SEC, Interactive Brokers failed...more

Katten Muchin Rosenman LLP

Bridging The Week - March 2020 #2

Last week, international regulators began issuing guidance and/or relief to impacted firms in response to the spread of COVID-19. The impact of this novel coronavirus has already begun materially to affect operations and...more

Eversheds Sutherland (US) LLP

Recent regulatory developments regarding AML requirements for broker-dealers

On October 11, 2019, the leaders of the US Securities and Exchange Commission (SEC), the US Commodity Futures Trading Commission (CFTC), and the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a...more

K&L Gates LLP

FinTech Forward: Blockchain, ICOs, and Cryptocurrencies

K&L Gates LLP on

In this episode, Jeremy McLaughlin and Dan Cohen discuss blockchain use cases, and the regulatory trends and associated frameworks for ICOs, and cryptocurrencies. In particular, they provide an overview of the application of...more

Ballard Spahr LLP

Court Decision Reinforces SAR Obligations of Penny Stock Clearing Brokers

Ballard Spahr LLP on

Second Post in a Two-Part Series - Opinion Stresses Importance of Narrative Sections and Supporting Documentation for SARs - In our first post in this series, we discussed the Securities and Exchange Commission’s...more

Ballard Spahr LLP

Clearing Broker Continues to Take Aim at SEC’s Ability to Enforce the BSA

Ballard Spahr LLP on

First Post in a Two-Part Series - On December 11, Judge Denise Cote of the Southern District of New York granted, in part, the Securities and Exchange Commission’s (“SEC”) motion for summary judgement in its action against...more

The Volkov Law Group

UBS Pays $15 Million for AML Compliance Deficiencies

The Volkov Law Group on

UBS Group agreed to pay a combined $15 million penalty to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”)and the SEC for regulatory deficiencies in its anti-money laundering compliance program. ...more

Orrick, Herrington & Sutcliffe LLP

The SEC's Authority to Enforce the BSA Is Challenged

In the past few years, the SEC has become increasingly active in bringing enforcement actions based on broker-dealers' alleged failures to comply with requirements of the Bank Secrecy Act (BSA), in particular that requirement...more

Ballard Spahr LLP

Continued Individual Liability Under the Bank Secrecy Act: The SEC Targets Two AML Compliance Officers and One CEO for Alleged...

Ballard Spahr LLP on

A recent anti-money laundering (“AML”) enforcement action reminds us of the increasing risk of individual liability for alleged violations of the Bank Secrecy Act (“BSA”), a key issue about which we have blogged....more

Carlton Fields

Chief Compliance Officers Beware

Carlton Fields on

In recent years, financial regulators have increasingly taken enforcement action against chief compliance officers (CCOs) and others in compliance oversight roles, rather than just against their employers....more

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