On Dec. 29, 2022, President Biden signed into law H.R. 2617, the “Consolidated Appropriations Act of 2023.” Among the routine federal funding provisions, Title V of the bill, the “Small
Continue Reading Congress Codifies Longstanding M&A Broker Exemption from SEC Registration
On Dec. 14, 2022, Gary Gensler, Chair of the U.S. Securities and Exchange Commission (SEC), released a statement announcing a proposal to establish an SEC rule setting forth a best
Continue Reading SEC Proposes to Establish a New Best Execution Standard
The Financial Industry Regulatory Authority (FINRA) in November 2022 released a targeted exam letter pertaining to communications for crypto products and services. The relevant period for this exam is July
Continue Reading FINRA Targeting Crypto Asset Retail Communications
On March 28, 2022, the Securities Exchange Commission (SEC) issued a press release regarding two proposed rules, Rules 3a5-4 and 3a44-2 under the Securities Exchange Act of 1934 (the Act).
Continue Reading SEC Seeks to Expand ‘Dealer’ or ‘Government Securities Dealer’ Definition to Require Additional Firms to Register with Agency and Comply with Federal Securities Regulations
On Oct. 7, 2020, the U.S. Securities and Exchange Commission (SEC) held an open meeting and issued a notice proposing a conditional exemption from securities broker-dealer registration under Section 15
Continue Reading SEC Proposes Exemption from Registration for Finders
On Sept. 25, 2020, the SEC issued a No-Action Letter to FINRA, in response to a previously issued Joint Statement by the SEC and FINRA. This No-Action Letter detailed how
Continue Reading SEC Issues No-Action Letter Facilitating the Secondary Trading of Digital Assets
Yesterday, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published responses to three frequently asked questions (“FAQs”) regarding customer due diligence requirements for “covered financial institutions” (
Continue Reading FinCEN Issues FAQs Regarding Customer Due Diligence Requirements
In the last decade, traditional financial institutions such as banks and broker-dealers have faced increased scrutiny from federal regulators and prosecutors related to the adequacy of their anti-money laundering (AML)
Continue Reading AML Compliance Scrutiny of Virtual Currency Services in 2020 and Beyond
The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released its annual list of 2020 Examination Priorities on Jan. 7, 2020. Many of
Continue Reading 2020 SEC Exam Priorities for Securities Industry Registrants
The SEC’s Division of Trading and Markets and the Office of the General Counsel of FINRA (Financial Industry Regulatory Authority) published on July 8, 2019, a joint staff statement (Custody
Continue Reading SEC/FINRA Joint Statement on Broker-Dealer Custody of Digital Assets