On Sept. 4, 2024, FinCEN adopted the IA AML Rule, which added certain registered investment advisers (RIAs) and exempt reporting advisers (ERAs and with RIAs, collectively, Covered Advisers) to the definition of “financial institution” under the regulations implementing the Bank Secrecy Act, as amended (BSA), effective Jan. 1, 2026.

Click here to read the full GT Alert.

Tags: AML, anti-money laundering, FinCEN, GT Insight
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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 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 Catherine Yepes Catherine Yepes

Catherine Yepes focuses her practice on financial services, representing financial institutions, including domestic and foreign banks and money services businesses (such as money transmitters). Catherine has represented clients before regulatory agencies such as the Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement…

Catherine Yepes focuses her practice on financial services, representing financial institutions, including domestic and foreign banks and money services businesses (such as money transmitters). Catherine has represented clients before regulatory agencies such as the Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN), Florida Office of Financial Regulation (OFR), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC).

Catherine advises clients on Bank Secrecy Act compliance, with an emphasis on anti-money laundering issues. She handles business, licensing, regulatory, and compliance matters for financial institutions. Her work includes performing independent risk assessments, developing anti-money laundering and sanctions compliance programs, preparing voluntary self-disclosures and specific license applications for submission to OFAC, and assisting with enforcement actions and subpoenas. Catherine also drafts, negotiates, and reviews commercial agreements and terms and conditions.

Catherine previously served as a Staff Attorney at the Third District Court of Appeal in Miami, where she analyzed trial records, researched legal principles, attended oral arguments and assisted in drafting opinions. She also gained experience in appellate litigation during her time as an academic intern with the Supreme Court of Florida in Tallahassee.

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Photo of Tiffanie Monplaisir Tiffanie Monplaisir

Tiffanie Monplaisir is a Practice Group Attorney in the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the

…

Tiffanie Monplaisir is a Practice Group Attorney in the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal and state regulatory landscape governing payments, lending, licensing, and consumer financial services. Tiffanie’s practice includes advising banks, FinTech and digital payment companies, money services businesses, payment processors, cryptocurrency businesses, and digital asset companies on a wide range of regulatory matters including licensing, crafting innovative solutions for Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance programs and related policies and procedures. Tiffanie also works on nationwide state money transmitter, lending, servicing, and other license acquisition projects.

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