Client Alert

On Aug. 5, 2026, the Securities and Exchange Commission announced a new specialized unit within its Division of Enforcement focused on accounting and financial reporting fraud, as well as broader misconduct in the accounting and auditing areas.

Continue Reading SEC Creates Financial Reporting and Accounting Unit in Enforcement Division

In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.”
Continue Reading Federal and State Efforts Intensify Focus on ‘Debanking’

In October’s GT Alert on non-bank lending, we focussed on whether there was a justification in banks being subject to regulatory capital requirements when non-bank financial institutions (NBFIs) were not.

Continue Reading Non-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?

On Sept. 30, 2025, the OFR requested approval from the Florida Financial Services Commission to publish a Notice of Proposed Rule to amend Rules 69U-100.323 and 69U-100.3231 and for final

Continue Reading Florida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking Rules

On Sep. 8, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it issued a new Geographic Targeting Order (September GTO) that renewed and modified FinCEN’s GTO announced on March 11, 2025 (March GTO).
Continue Reading Deadline Quickly Approaching for Newly Covered MSBs To Comply with FinCEN’s Southwest Border GTO

On June 16, 2025, the Senate Finance Committee released its own version of the tax provisions of H.R. 1, entitled the “One Big Beautiful Bill Act,” which the U.S. House of Representatives passed on May 22, 2025. The full U.S. Senate is expected to debate the Senate Proposal in the days ahead, where additional changes may be made.
Continue Reading One Big Beautiful Bill Act – Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers Abroad

On Jan. 23, 2025, the U.S. Supreme Court granted the U.S. government’s request for a stay (SCOTUS Order) of the nationwide preliminary injunction of the Corporate Transparency Act (CTA) issued

Continue Reading CTA UPDATE: Enforcement Remains Suspended Despite U.S. Supreme Court Granting Stay of Preliminary Injunction

In late 2024, the United Kingdom’s Financial Conduct Authority (FCA) published a “Dear CEO” letter related to the FCA’s “Custody and Fund Services Supervision Strategy.” The letter shares the FCA’s

Continue Reading UK FCA Letter Expresses Concerns About Fund Service Providers

In October 2024, the California DFPI finalized regulations for providers of income-based advances (Earned Wage Access or EWA), clarifying registration requirements under the California Consumer Financial Protection Law (CCFPL). These

Continue Reading California DFPI Finalizes New Earned Wage Access Regulations