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Investment Advisers Prepare: The BSA is Here

On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more

Data Protection Demands Complicate CTA Compliance

On Jan. 1, the Corporate Transparency Act (CTA) went into effect, premised on the belief that illicit actors use corporate structures like shell companies and fronts to hide their identities and launder criminal proceeds...more

U.S. Treasury Issues Notice of Anti-Money Laundering Regulations for Residential Real Estate Transfers

On Feb. 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM)1 in response to illicit finance risks identified in the U.S. residential real estate...more

Reporting Companies Under the Corporate Transparency Act Beware: Using Service Providers to Comply Creates New Data Privacy Risk

The Corporate Transparency Act (CTA), which became effective on January 1, requires that U.S. and foreign companies authorized to do business in the U.S. (each, a Reporting Company) report specific personal information...more

AML Best Practices for Private Funds: Red Flags and Responses for Private Funds

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

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