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Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Alston & Bird

Navigating AI-Related Disclosure Challenges: Securities Filing, SEC Enforcement, and Shareholder Litigation Trends

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Companies’ accelerating reliance on artificial intelligence (AI) means heightened Securities and Exchange Commission (SEC) and shareholder plaintiff scrutiny. Our Securities Litigation Group underscores what companies need to...more

Mayer Brown Free Writings + Perspectives

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more

Ballard Spahr LLP

Treasury Issues Broad National Strategy for Combatting Illicit Financing

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Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

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On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Jackson Lewis P.C.

SEC to Advisors and Funds – Adopt and Implement Cybersecurity Policies and Procedures

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On February 9, the Securities and Exchange Commission (“SEC”) voted to propose rule 206(4)-9 under the Advisers Act and 38a-2 under the Investment Company Act (collectively, “Proposed Rule”). In general, the Proposed Rule...more

Goodwin

Sustainable Finance In Luxembourg — What Managers Should Do Now

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Regulation (EU) 2019/2088 of 27 November, 2019 on sustainability-related disclosures in the financial services sector, as amended by Regulation (EU) of 18 June, 2020 on the establishment of a framework to facilitate...more

A&O Shearman

UK Conduct Regulator Concludes No Changes Needed to Banking Senior Managers Regime

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The U.K. Financial Conduct Authority has published the findings of its review into the implementation of the Senior Managers and Certification Regime for the banking sector. The SM&CR came into force for banking firms in...more

Troutman Pepper

Treasury Report Addresses Regulatory Approaches Affecting Investment Companies and Their Advisers

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As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...more

Carlton Fields

OCIE Lessons From Cybersecurity 2 Initiative

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On August 7, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert containing observations from its Cybersecurity 2 Exam Initiative. As a follow-up to the 2014 Cybersecurity 1 initiative, the...more

Skadden, Arps, Slate, Meagher & Flom LLP

OCIE Releases Results of Cybersecurity Examination Initiative

On August 7, 2017, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a summary of its observations (the report) from cybersecurity examinations of 75...more

Ballard Spahr LLP

Colorado Proposes Cybersecurity Rules for Investment Advisers, Broker-Dealers

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The Colorado Division of Securities recently issued proposed rules directed at establishing cybersecurity requirements for broker-dealers and investment advisers. The proposed rules were issued only a month after New York...more

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