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FinTech Focus: Investment Advisers Join Ranks of Financial Institutions Subject to the Bank Secrecy Act

Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network...more

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more

Client Alert: New York Issues Significant Amendments to its Forward-Leaning Cyber Regulations

In 2017, the New York Department of Financial Services (“NYDFS”) enacted a landmark regulation requiring financial services institutions such as banks and insurance companies in the state to meet substantial cybersecurity...more

Client Alert: California Enters the Arena of Virtual Currency Regulation

After prolonged deliberation, California has finally decided to enter the virtual currency regulatory arena by adopting two virtual currency regulatory bills into law. The California Digital Financial Assets Law (“DFAL”),...more

Client Alert: New multi-front Enforcement Action Emphasizes Key AML Compliance Requirements

Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more

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