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Hogan Lovells

Art, sanctions and suspicion: What the Ojiri case tells us about risk and responsibility in the regulated sector

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The recent conviction of London-based art dealer Oghenochuko Ojiri marks a watershed moment for financial crime enforcement in the UK's regulated sector. For the first time, a conviction has been secured under section 21A of...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Morrison & Foerster LLP

FinCEN Expands its Reach with Final Rules for Investment Advisers and the Residential Real Estate Sector

Key Takeaways - •FinCEN has issued two new final rules to significantly expand regulation around certain investment adviser and residential real estate sectors to combat illicit finance in these areas. These highly...more

Holland & Knight LLP

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

Ballard Spahr LLP on

On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...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

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

K2 Integrity on

Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

A&O Shearman

FINRA Issues 2019 Annual Risk Monitoring and Examination Priorities Letter, Highlighting Potential Areas Of Enforcement Risk

A&O Shearman on

On January 22, 2019, the Financial Industry Regulatory Authority (“FINRA”) issued its annual letter describing its current risk monitoring and examination priorities. See FINRA, Risk Monitoring and Examination Priorities...more

The Volkov Law Group

AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions

The Volkov Law Group on

Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations.  With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more

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