After years of rulemaking efforts, FinCEN issued a Notice of Proposed Rulemaking (Proposed Rule) Feb. 15, 2024, that would subject certain investment advisers to AML/CFT compliance requirements under the BSA. The Proposed Rule’s comment period runs through April 15, 2024. Covered investment advisers would be required to comply within 12 months from the final rule’s effective date.

Continue reading the full GT Alert.

Tags: banking and finance, Financial Regulation and Compliance, FinCEN, FRAC, GT Insight, investment management
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Photo of Richard M. Cutshall Richard M. Cutshall

Richard M. Cutshall is Co-Chair of the firm’s Investment Management Group. Rich has experience representing clients in a variety of investment management, corporate, and general securities matters, including the representation of mutual funds and other funds registered under the Investment Company Act of…

Richard M. Cutshall is Co-Chair of the firm’s Investment Management Group. Rich has experience representing clients in a variety of investment management, corporate, and general securities matters, including the representation of mutual funds and other funds registered under the Investment Company Act of 1940, fund independent directors, unregistered investment companies, federally registered and state registered investment advisers, broker-dealers, and an array of public and private companies. He represents clients in all aspects of investment company practice, including organizing and forming new funds, registering investment companies with the SEC, the acquisition and merger of funds, and advising clients on the day-to-day aspects of corporate governance, board and adviser fiduciary responsibility, and SEC compliance.

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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Kyle R. Freeny Kyle R. Freeny

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations,

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Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations, and anti-money laundering (AML) and international corruption matters.

Kyle was one of 19 prosecutors selected by Robert S. Mueller III to conduct the high-profile investigation into alleged Russian election interference, coordination between Russian officials and the Trump campaign, and related matters. As Assistant Special Counsel, Kyle played a lead role in federal tax and bank fraud investigations, as well as a money laundering investigation into the funding of Russian intelligence cyber intrusions during the 2016 Presidential election using cryptocurrency.

While at the Department of Justice, Kyle was involved in investigations relating to major international money laundering and corruption matters, including matters involving the Bank Secrecy Act (BSA), Foreign Corrupt Practices Act (FCPA), and foreign banking and corruption laws designated as predicates to U.S. money laundering charges. Kyle has considerable experience handling cross-border issues and coordinating with foreign law enforcement authorities and U.S. and foreign regulators on complex transnational financial cases.

Kyle has also represented dozens of federal agencies in high-profile litigation, including the Office of Foreign Assets Control (OFAC), the Department of Defense, and the Federal Financing Bank. Kyle has appeared before federal trial courts across the country.

‡ Admitted in California. Practice in the District of Columbia limited to matters and proceedings before Federal courts and Agencies.

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Photo of Melissa Peach Melissa Peach

Melissa Peach, a member of Greenberg Traurig’s Corporate Practice in New York, concentrates her practice on fund formation and investment management. Melissa represents clients in matters involving the formation, structuring, management, and related legal issues for a wide range of domestic and international

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Melissa Peach, a member of Greenberg Traurig’s Corporate Practice in New York, concentrates her practice on fund formation and investment management. Melissa represents clients in matters involving the formation, structuring, management, and related legal issues for a wide range of domestic and international investment funds. She also has experience representing clients in connection with investments in private funds and secondary transaction matters.

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Photo of Janiell "Alexa" Gonzalez Janiell "Alexa" Gonzalez

Janiell A. Gonzalez focuses her practice on digital payments, money service businesses, money transmitter licensing, lender licensing, escrow licensing, and providing federal and state regulatory compliance guidance to cryptocurrency businesses, digital payment companies, fintechs, consumer and commercial lending companies, and banks. Janiell’s compliance…

Janiell A. Gonzalez focuses her practice on digital payments, money service businesses, money transmitter licensing, lender licensing, escrow licensing, and providing federal and state regulatory compliance guidance to cryptocurrency businesses, digital payment companies, fintechs, consumer and commercial lending companies, and banks. Janiell’s compliance related focus includes advice on matters concerning compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, the Corporate Transparency Act and implementing regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs.

She also advises clients on matters involving the Consumer Financial Protection Bureau (CFPB) and other federal and state regulatory authorities with oversight of consumer financial and payments products and services. Janiell has a wide-ranging background in regulated entity compliance matters having served as an in-house corporate paralegal for large corporations in the health care and aviation industries. She now leverages this experience to provide strategic, practical and actionable advice to clients.

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