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FinCEN Re-Proposes AML/CFT Requirements Covering Investment Advisers

On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more

CFTC Year in Review: 23 Takeaways From 2023 and Predictions for 2024

At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more

SEC Adopts New Rules That Will Require More Market Participants to Register as Dealers

On February 6, 2024, by a vote of 3-2 along party lines, the Securities and Exchange Commission (the SEC or the Commission) adopted Rules 3a5-4 and 3a44-2 under the Securities Exchange Act of 1934 (the Exchange Act), which...more

SEC Makes Sweeping Changes to Private Fund Adviser Regulatory Regime: Mandates Quarterly Reporting, Restricts Preferential...

In a 3-2 vote on August 23, 2023, the Securities and Exchange Commission (“SEC” or “Commission”) adopted five new rules under the Investment Advisers Act of 1940 (the “Advisers Act”), collectively called the “Private Fund...more

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