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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

SEC and FinCEN Propose Customer Identification Obligations for Investment Advisers

On May 13, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a joint notice of a proposed rulemaking (NPRM) that would require...more

Gensler Warns of Increased SEC Requirements for Private Funds

On May 25, 2023, Gary Gensler, Chairperson of the U.S. Securities and Exchange Commission (SEC), spoke at an Investment Company Institute leadership conference and discussed SEC proposals that address potential instability in...more

Regulators Crack Down on the Use of Messaging Apps as Wall Street Banks and Investment Advisers Hit With $1.8 Billion in Fines

On September 27, 2022, regulators from the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) handed out over $1.8 billion in fines to financial institutions in connection with...more

OFAC Designates Tornado Cash as a Sanctioned Entity as Federal Government Continues to Increase Regulation of Decentralized...

On Aug. 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned cryptocurrency mixer Tornado Cash for allegedly helping launder more than $7 billion worth of cryptocurrency over three years.1...more

Fifth Circuit Requires Jury Trials for SEC Fraud Defendants

On May 18, the U.S. Court of Appeals for the Fifth Circuit held that defendants in SEC enforcement actions for fraud are entitled to jury trials in federal court rather than simply appearing before an SEC administrative law...more

The First FCPA Resolution of 2022 Revisits Old Themes

On February 17, 2022, KT Corporation (KT, formerly known as Korea Telecom) resolved a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission (SEC) related to corruption schemes in...more

Best Practices To Ensure DPA Compliance After Ericsson

On Oct. 21, Ericsson Inc. disclosed that the U.S. Department of Justice asserted that the company had "breached its obligations" under a 2019 deferred prosecution agreement "by failing to provide certain documents and factual...more

Competitor Recovers Damages From FCPA Violator In Post-Enforcement Civil Litigation

On Wednesday, May 12, 2021, Swedish telecommunications manufacturer Ericsson announced that it had reached an €80 million ($96.66 million) settlement with one of its competitors to compensate for commercial damages the...more

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