The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more
U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds)2 and their U.S. general partners, sponsors, and managers (Advisers) are not directly subject to the Bank Secrecy Act of 1970...more
7/26/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
FATF ,
Fund Managers ,
Hedge Funds ,
Office of Foreign Assets Control (OFAC) ,
Politically Exposed Person (PEPs) ,
Popular ,
Private Funds ,
Red Flags Rule ,
SDN List ,
Venture Capital
On September 29, 2022, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements...more
4/6/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Corruption ,
Exemptions ,
Final Rules ,
FinCEN ,
Fraud ,
IRS ,
Ownership Interest ,
Popular ,
Reporting Requirements ,
Smaller Reporting Companies ,
Tax Exemptions ,
Terrorism Funding
Silicon Valley Bank, Santa Clara, California, was closed on March 10 by the California Department of Financial Protection and Innovation (CDFPI). On March 12, the New York State Department of Financial Services (NYSDFS)...more
I. Introduction-
U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds),1 and their U.S. general partners, sponsors, and managers (Advisers), are not directly subject to the...more
2/20/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
FinCEN ,
Fund Managers ,
Hedge Funds ,
Investment Adviser ,
Money Laundering Control Act (MLCA) of 1986 ,
Office of Foreign Assets Control (OFAC) ,
Private Funds ,
Securities and Exchange Commission (SEC) ,
Venture Capital
On January 18th, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first action (the Order) pursuant to Section 9714 of the Combating Russian Money Laundering Act1 to designate...more