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
9/17/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
National Security ,
Registered Investment Advisors
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
5/21/2024
/ AML/CFT ,
Anti-Money Laundering ,
Asset Management ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Comment Period ,
FinCEN ,
Investment Adviser ,
New Rules ,
Public Comment ,
Registered Investment Advisors ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Assessment ,
Risk Management ,
Securities and Exchange Commission (SEC)
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
2/22/2024
/ AML/CFT ,
Anti-Money Laundering ,
Asset Management ,
Bank Secrecy Act ,
BSA/AML ,
FinCEN ,
Investment Adviser ,
National Security ,
Proposed Regulation ,
Proposed Rules ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
On August 2, in its first ever cryptocurrency enforcement action, the New York State Department of Financial Services ("NYDFS") announced it had imposed a $30 million fine on Robinhood Crypto, LLC ("RHC") for failures in its...more
8/15/2022
/ Bank Secrecy Act ,
BSA/AML ,
Business Licenses ,
Consent Order ,
Cryptocurrency ,
Enforcement Actions ,
New York ,
Noncompliance ,
Notice Requirements ,
NYDFS ,
Regulatory Violations ,
State and Local Government ,
Virtual Currency
On December 3, 2019, in a rare public statement regarding the provision of banking services to cannabis- or hemp-related businesses, the Federal Banking Agencies, including the Board of Governors of the Federal Reserve...more
12/11/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Controlled Substances Act ,
Farm Bill ,
Federal Bank Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Hemp ,
Hemp Related Businesses ,
Interagency Guidance ,
Joint Statements ,
NCUA ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
USDA
On September 25, 2019, the US House of Representatives ("House") passed, by a vote of 321 to 103, the Secure and Fair Enforcement Banking Act ("SAFE Banking Act"), bipartisan legislation designed to secure and regulate...more
10/9/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Canada ,
Cannabis Products ,
Cannabis-Related Businesses (CRBs) ,
Cole Memorandum ,
Controlled Substances Act ,
Cross-Border Transactions ,
Department of Justice (DOJ) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Harmonization Rules ,
Hemp ,
Marijuana Related Businesses ,
Medical Marijuana ,
NYDFS ,
Popular ,
Proposed Legislation ,
Rohrabacher-Farr Amendment ,
Suspicious Activity Reports (SARs) ,
USDA