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
Earlier this month, approximately one year after releasing its proposed amendments to Regulation S-P, the SEC announced the adoption of final amendments to Regulation S-P, expanding the information protected, the policies and...more
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
5/20/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
Customer Identification Program (CIP) ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Investment Adviser ,
NPRM ,
Popular ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
In its latest attempt, the U.S. Department of Treasury, Financial Crimes Enforcement Network (“FinCEN”), will require certain investment advisers to implement compliance measures to detect and report suspected money...more
In recent guidance, the Financial Industry Regulatory Authority (FINRA) published the results of its targeted examination or “sweep” of crypto assets retail communications distributed or issued by its member firms, finding...more
As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more
1/12/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Due Diligence ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
FinCEN ,
Governance Standards ,
NYDFS ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Agenda ,
Remediation ,
Self-Reporting ,
Third-Party ,
UDAAP
With the start of the new year, FinCEN’s Beneficial Ownership Reporting Rule (BOI Reporting Rule) came into effect, implementing specific transparency requirements relating to corporate ownership. The BOI Reporting Rule...more
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
10/25/2023
/ California ,
Cryptocurrency ,
Department of Financial Protection and Innovation (DFPI) ,
Digital Assets ,
Digital Currency ,
Financial Regulatory Reform ,
Governor Newsom ,
New Legislation ,
New Regulations ,
Regulatory Agenda ,
Regulatory Requirements ,
State and Local Government ,
Virtual Currency
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
10/12/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Cryptoassets ,
Cryptocurrency ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
FinCEN ,
FinTech ,
New York ,
NYDFS
The New York Department of Financial Services (NYDFS) proudly announced an “update on [its] two-year transformational initiative to strengthen NYDFS’ nation-leading virtual currency oversight” on September 18, 2023. Although...more
10/9/2023
/ Bitcoin ,
Comment Period ,
Corporate Governance ,
Cryptoassets ,
Cryptocurrency ,
New Guidance ,
NYDFS ,
Public Comment ,
Regulatory Agenda ,
Regulatory Requirements ,
Virtual Currency