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Carlton Fields

Adviser Loses Customer Crypto: Wallet Key Custody Not Airtight

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On June 25, 2024, a final judgment was entered by a federal district court against investment adviser Lufkin Advisors LLC and its principal, Chauncey Lufkin, for losing access to a crypto wallet used to manage a client’s...more

Proskauer - Regulatory & Compliance

New filing deadlines for Schedule 13G effective September 30

The deadlines for filing and amending Schedule 13Gs are about to change, and regular 13G amendments will now be due on a quarterly basis instead of annually. As we discussed in our alert last fall (available here), in...more

Fenwick & West LLP

New Schedule 13G filing deadlines looming

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New filing deadlines for Schedule 13G become effective on September 30. In October 2023, the SEC adopted new rules governing beneficial ownership reporting, including accelerating the filing deadlines for Schedule 13G and...more

SEC Compliance Consultants, Inc. (SEC³)

Top Tips for Updating Your 2024 Compliance Program

Every year compliance officers face the unenviable job of performing their compliance program's annual review under Advisers Act Rule 206(4)-7). An essential element of that review is updating the firm's compliance policies...more

Sheppard Mullin Richter & Hampton LLP

Hospitality Alert: Quick Facts on the Corporate Transparency Act

Whether you are a hotel owner, operator, or developer, or anyone who has an interest in an LLC, corporation, or limited partnership, you should be aware of your new compliance obligations under the Corporate Transparency Act...more

Dechert LLP

Treasury Proposes Investment Advisers AML/CFT Program Rule

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Treasury proposed a new rule that would require investment advisers to establish an AML/CFT program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Proposed Rule). The Proposed Rule...more

Seward & Kissel LLP

FinCEN's New Rule on Beneficial Ownership Information Reporting Requirements: Application to Investment Advisers and Related...

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January 1, 2024 is the effective date of a new rule (the “BOI Reporting Rule”) issued under the Corporate Transparency Act requiring domestic and foreign corporations, limited liability companies and other similar entities...more

Kohn, Kohn & Colapinto LLP

FinCEN’s New Rules for Reporting Beneficial Owners Create Opportunity for Whistleblowers

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is enacting new rules for January 1, 2024, requiring companies to report their beneficial owners to FinCEN. Violations of these new...more

Akin Gump Strauss Hauer & Feld LLP

Corporate Transparency Act: New Beneficial Ownership Reporting Requirements Starting January 1, 2024

Key Points - The Corporate Transparency Act (the “CTA”), implemented primarily through a rule published by FinCEN on September 30, 2022, the Beneficial Ownership Information Reporting Rule (“BOIR Rule”), becomes effective...more

Polsinelli

Ownership Transparency Continues for Skilled Nursing Facilities with Additional Required Disclosures

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On November 15, 2023, CMS finalized a proposed rule that will require Skilled Nursing Facilities (“SNFs”) to disclose the identity of an expanded array of ownership and control interests in SNFs beyond the information that is...more

Pillsbury Winthrop Shaw Pittman LLP

SEC Adopts Rule Changes to Shareholder Ownership Reporting

The SEC shortened Schedule 13D and Schedule 13G beneficial ownership reporting deadlines and amended disclosure requirements. The SEC modified and accelerated the initial filing and amendment deadlines, as well as...more

Paul Hastings LLP

Public Company Watch: October 2023

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In the October edition of our Public Company Watch, we cover key issues impacting public companies, including the SEC adopting rules modernizing beneficial ownership reporting and short sale reporting, and issuing new C&DIs...more

Vinson & Elkins LLP

Shorter Schedule 13D and Schedule 13G Filing Deadlines and New Guidance: SEC Adopts Final Rules Amending Beneficial Ownership...

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On October 10, 2023, the Securities and Exchange Commission (“SEC”) adopted amendments to the rules governing beneficial ownership1 reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (the...more

Dorsey & Whitney LLP

RIA Regulatory Review - October 2023

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This RIA Regulatory Review highlights certain key regulatory developments affecting investment advisers. Please contact us with any questions on the topics covered below. The SEC Adopts Significant New Rules for Private...more

Conyers

Conyers Coverage Summer 2023 – Issue 9 – Cayman Islands

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A warm welcome to our latest edition of Conyers Coverage. It’s been a dizzying year to date for the Cayman Islands (re)insurance industry, so it’s time for some updates and insights. The momentum is real and the pipeline...more

Foster Swift Collins & Smith

Corporate Transparency Act: What You Need to Know Before 2024

Introduction and Scope of New Rule - With a stated goal of countering money laundering, the financing of terrorism and other illicit activities (including those of Russian oligarchs currently under U.S. sanctions),...more

Orrick, Herrington & Sutcliffe LLP

What You Need to Know About the SEC’s Amendments to Enhance Investor Protections Concerning Insider Trading

During an open meeting held December 14, 2022, the SEC voted unanimously in favor of adopting changes to the rules governing insider trading defenses, including amendments to Rule 10b5-1 under the Securities Exchange Act of...more

Kramer Levin Naftalis & Frankel LLP

SEC Adopts New Conditions and Disclosures Regarding 10b5-1 Plans

On Dec. 14, 2022, the Securities and Exchange Commission (SEC) adopted amendments to Rule 10b5-1, generally in the form issued for comment in January 2022 (replacing the version initially published on Dec. 15, 2021), which we...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

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In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Blank Rome LLP

[Webinar] New Corporate Transparency Rules Taking Shape: What Should Businesses Expect? - February 2nd, 12:30 pm - 1:00 pm ET

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For the first time in decades, Congress in 2021 enacted major reform to anti-money laundering laws. A central piece of this legislation was the Corporate Transparency Act, which promised to increase companies’ obligations to...more

BCLP

Additional Compliance for the Art World

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Individuals, trusts and companies buying or selling art via UK galleries and auction houses will now be subject to the same customer due diligence checks as those opening bank accounts in the UK. What has changed? The...more

Bass, Berry & Sims PLC

Everything Public Companies Need to Know About Recent SEC Amendments

Nearly a year and a half after proposing them, the SEC recently adopted amendments to disclosure requirements for reporting companies, as mandated by the 2015 Fixing America’s Surface Transportation Act (the FAST Act). These...more

Vedder Price

BSA/AML Alert: The Beneficial Ownership Rule Becomes Effective Today

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On May 11, 2018, the beneficial ownership rule became fully effective. While the rule was finalized on July 16, 2016, compliance was not mandatory until May 11, 2018. The delay in implementation was to permit covered...more

Sullivan & Worcester

Customer Due Diligence and FinCEN’s Frequently Asked Questions

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As you are aware, FinCEN’s Customer Due Diligence rules are effective in two days. In a nutshell, these rules require banks to obtain and verify the identity of the beneficial owners of new business customers. The rules are...more

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