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K&L Gates LLP

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

K&L Gates LLP on

Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

Seward & Kissel LLP

FinCEN Proposes AML Requirements for Certain Investment Advisers

Seward & Kissel LLP on

On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

ArentFox Schiff on

On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

King & Spalding

OFAC Publishes “A Framework for Compliance Commitments”

King & Spalding on

OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program - On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more

The Volkov Law Group

Anti-Money Laundering Risks for Global Companies (Part I of III)

The Volkov Law Group on

Non-financial institution companies operating in the global marketplace face ever-increasing risks of money laundering. Sophisticated criminal organizations have developed their own mechanisms and strategies to skirt money...more

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