FinCEN seeks to safeguard the investment adviser sector from illicit finance as evidenced by the issuance of the Final Investment Adviser Rule on 8/28/24 with a compliance date of 1/1/26. The investment adviser sector final...more
Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more
El 02/23/24, el Grupo de Acción Financiera Internacional (GAFI o “FATF”), una entidad intergubernamental independiente que desarrolla políticas para la protección de nuestro sistema financiero global contra el lavado de...more
On 2/23/24, the Financial Action Task Force (FATF), an independent inter-governmental entity that develops policies for protection of our global financial system from money laundering, terrorist financing and financing of...more
El 15 de febrero de 2024, FinCEN publicó un Aviso de Reglamentación Propuesta (NPRM) que requeriría que ciertos asesores de inversiones (Investment Advisers) apliquen requisitos de ALD/FT conforme con la Ley de Secreto...more
On 2/15/24, FinCEN published a Notice of Proposed Rulemaking (NPRM) that would require certain investment advisers to apply AML/CFT requirements pursuant to the Bank Secrecy Act, including implementing risk-based AML/CFT...more
February 29, 2024- The Federal Reserve Bank of New York has released a case study focused on pension fund investments in affordable apartments. February 29, 2024- The Financial Action Task Force (FATF) issued an...more
January 1, 2024 is quickly approaching and it will be a milestone for small businesses and their owners. Why? Because it is the effective date of the Corporate Transparency Act (the “Act”) – historic legislation that requires...more
In an effort to curb money laundering, tax evasion, and other corrupt activities conducted through shell companies and synthetic identities, the world’s developed nations have worked for over a decade to create a system of...more
On June 29, FinCEN announced that the Financial Action Task Force (FATF) issued a public statement updating its lists of jurisdictions with strategic deficiencies in anti-money laundering (AML), countering the financing of...more
On June 27, a broad lineup of U.S. government departments and agencies issued an “Africa Gold Advisory.” The 29-page Advisory, jointly issued by the U.S. Departments of State, Treasury, Commerce, Homeland Security, and Labor,...more
The bipartisan bill would provide a federal safe harbor for non-custodial blockchain service providers from state money transmission and digital asset licensing laws. On March 23, 2023, US House of Representatives...more
On March 9, FinCEN informed U.S. financial institutions that last month the Financial Action Task Force (FATF) suspended the Russian Federation’s membership after determining that the country’s “actions unacceptably run...more
The Financial Action Task Force (FATF) has greylisted South Africa, along with Nigeria, for insufficient regulation of financial crimes like money laundering and terrorist financing. South Africa is the second G20 nation...more
October 31, 2022- Securities and Exchange Commission Commissioner Caroline A. Crenshaw gave remarks at the inaugural ECGI Responsible Capitalism Summit entitled, "Moving Forward in Our Lane."...more
Domestic terrorism is not a new threat in America, but in recent years we have seen a significant and horrific increase in violent attacks and activities carried out by individuals and groups motivated by a range of radical...more
On 14 September 2022, K2 Integrity hosted a webinar on considerations in the digital assets space. K2 Integrity Board Member Christopher Brummer and AML/CFT experts Mariano Federici and Alex Levitov discussed the current...more
As we have repeatedly blogged, concerns about perceived anti-money laundering (“AML”) risks in the real estate industry are rising globally. Consistent with this concern, the Financial Action Task Force (“FATF”) has updated...more
There is no doubt 2022 has signalled a renewed focus on beneficial ownership transparency. White & Case partners Jonah Anderson and Anneka Randhawa, and associate Laura Higgins have collaborated with Hannah Lilley and Michael...more
In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more
The extension of the Financial Action Task Force (FATF) ‘Travel Rule’ to ‘Virtual Asset Service Providers’ (VAPSs) is emblematic of the continued and growing push to bring crypto businesses into the mainstream of financial...more
The Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (Notice) on Dec. 9, 2021, requesting public comment on ways to enhance the transparency of the domestic real estate market...more
In late October, the Financial Action Task Force issued its long-awaited updated guidance on Virtual Assets and Virtual Asset Service Providers (“FATF Guidance”), an extremely lengthy and detailed document setting forth how...more
Key considerations for banks engaging with governments and peer institutions to improve financial crime compliance systems - Every year, banks spend billions of dollars on core financial crime compliance systems and are...more
The Financial Crimes Enforcement Network (“FinCEN”) has been busy during the last few weeks – and presumably will remain busy for the rest of 2021, as it attempts to satisfy numerous mandates imposed by the Anti-Money...more