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FinCEN Issues Final Sweeping AML Requirements for Registered Investment Advisers & ERAs

On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs

On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more

A View from Abroad: Unpacking DOJ’s M&A Safe Harbor Policy, Part II

On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more

The Economic Impact of FATF Grey-Listing

The Financial Action Task Force ("FATF") is the global standard-setter on anti-money laundering ("AML"), countering terrorist financing ("CFT") and counter proliferation financing. FATF's standards, also referred to as...more

Money Laundering Issues in the Art Market

In February 2023, the Financial Action Task Force (“FATF”), the global standard-setter on Anti-Money Laundering policy, issued a report describing the financial crime risks in the art and antiquities market, as well as good...more

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