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SEC and FinCEN Propose Rules to Impose Customer Identification Program Obligations on Certain Investment Advisers

On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more

New DOJ Pilot Program Incentivizes Individuals to Report Criminal Conduct

Companies beware! The U.S. Department of Justice (DOJ) announced a pilot program “designed to encourage voluntary self-disclosure by individual participants in certain types of criminal conduct involving corporations.” In...more

FinCEN Proposes AML/CFT Rules for Investment Advisers

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

On Watch - Do regulators now expect firms to monitor communications using AI?

Artificial Intelligence (AI) is no longer just a buzzword, but a reality that is firmly on the radar of regulators and regulated firms in the US and UK. Recently, considerable investment into this area has prompted...more

U.S. Health Care Industry Takes Note: U.S. Supreme Court 2023 Attention on False Claims Act

This Tuesday, April 18, 2023, the U.S. Supreme Court heard argument in U.S. v. SuperValu. SuperValu is the second – and more consequential – False Claims Act (FCA) case of the term....more

Fallout from the Glencore resolutions & lessons learned

On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more

Compliance Impact of FinCEN Statement of Priorities

At the direction of the President, FinCEN is intensifying its regulation of banks and fintechs across the spectrum of the laws that it is charged with enforcing. This past June, the White House published the Memorandum on...more

Sharper Lines Mean Tighter Nets: How the FinCEN’s Latest Priorities are Another Step to Increased Enforcement

In the latest sign that the federal enforcement apparatus is slowly but surely training its sights on white-collar professionals and businesses, particularly financial services, the Financial Crimes Enforcement Network...more

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