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The Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Treasury Department, has issued a proposed rule (the “Proposal”) that would subject certain investment advisers to anti-money laundering (“AML”)...more
On November 30, Massachusetts Attorney General Andrea Campbell (the “AGO”) unveiled a new proposed rule regulating “junk fees” and consumer subscriptions (the “Proposed Rule”). The Proposed Rule in large part mimics, and in...more
The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more
Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry. By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more
On October 11, the Consumer Financial Protection Bureau (CFPB or Bureau) published a special edition of its Supervisory Highlights report. This report serves as a “victory lap” for the Bureau, which highlights the relief it...more
On July 1, 2022, the US Department of Commerce (Commerce) published a proposed rule to pause the collection of any antidumping (AD) or countervailing (CVD) duties under its pending circumvention inquiries on crystalline...more
The Anti-Money Laundering Act of 2020 was a game-changing piece of legislation. Perhaps the most important provision is the expansion of beneficial ownership regulatory authority....more
On November 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a proposed rule with the objective of ensuring banks offer fair access to financial services. Certain banks have received significant...more
Financial institutions operating in New York — including New York state licensed banks, trust companies, private bankers, savings banks, savings and loan associations, branches of foreign banks, check cashers, and money...more