Is Edward Snowden a Whistleblower?
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more
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
Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more
On New Year’s Day, Congress overrode President Trump’s veto of the National Defense Authorization Act (NDAA) for the 2021 fiscal year, turning the bill into law without requiring the president’s signature. The NDAA includes...more
On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, which includes the Corporate Transparency Act (the CTA).1 The CTA requires all U.S. businesses to file “beneficial ownership”...more
On January 1, 2021, the US Senate voted to override President Donald Trump’s veto of H.R. 6395, the National Defense Authorization Act for Fiscal Year 2021 (NDAA). As part of the NDAA, the Anti-Money Laundering Act of 2020...more
Expanded compliance obligations will have far-reaching implications for regulated financial institutions and most companies operating in the US. On January 1, 2021, Congress overrode President Trump’s veto and enacted the...more
On May 11th, 2016, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the Treasury, published a Final Rule (the “Rule”) on customer due diligence after a four-year rulemaking process. The Rule...more