On April 16, 2025, the CFPB’s Chief Legal Officer, Mark R. Paoletta, issued a memorandum to CFPB staff that sets out the agency’s 2025 supervision and enforcement priorities.
Continue Reading CFPB Memo Details Less Oversight on Fintechs, Shift to State-Led Enforcement
The California Department of Financial Protection and Innovation (DFPI) on April 4, 2025, issued its formal notice of rulemaking for digital financial business regulation, following receipt of two sets of 2024 comments on its draft proposed rules for California’s “Digital Finance Assets Law” (DFAL) (AB 39 and SB 401, 2023).
Continue Reading California DFPI Issues Formal Rulemaking for Digital Financial Asset Regulation
FinCEN recently issued an alert to warn U.S. financial institutions, particularly depository institutions and money services businesses (MBSs), of the risks and red flags associated with bulk cash smuggling by Mexico-based drug cartels and other transnational criminal organizations.
On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule (Final Rule) extending the recordkeeping requirement for compliance with U.S. economic sanctions regulations from five to 10 years.
Continue Reading US Treasury Extends Recordkeeping Requirement for Economic Sanctions Compliance to 10 Years
On March 27, 2025, the Federal Trade Commission (FTC) filed a lawsuit and proposed settlement order resolving claims against Cleo AI, a fintech that operates a personal finance mobile banking application through which it offers consumers instant or same-day cash advances. The FTC alleges that Cleo deceived consumers about how much money they could get and how fast that money could be available, and that Cleo made it difficult for consumers to cancel its subscription service.
Continue Reading FTC Alleges Fintech Cleo AI Deceived Consumers
In 2021, the SEC adopted the Marketing Rule, and in 2023, issued an FAQ requiring private fund managers to show net-of-fees performance alongside gross performance. Managers found it difficult to calculate net performance for individual investments, as fees are generally charged at the fund level.
Continue Reading SEC’s Marketing Rule Updates May Provide Relief for Investment Managers
On March 20, 2025, the U.S. Securities and Exchange Commission took a step towards clarifying its position on crypto mining activities. In a recent statement, the SEC’s Division of Corporation Finance provided non-binding guidance on the application of federal securities laws to proof-of-work (PoW) mining activities, stating that such activities are beyond the SEC’s purview.
Continue Reading SEC Staff Clarifies Stance on Crypto Mining
The FCA has initiated significant engagement with the private funds sector, akin to its 2013 AIFMD implementation efforts. In 2025, it plans to streamline UK regulatory requirements for fund managers and review conflict of interest management, focusing on governance and investor protections.
Continue Reading FCA Review of Private Fund Market Valuation Practices
On March 21, 2025, FinCEN issued an interim final rule narrowing the scope of the CTA’s BOI Reporting Rule (Reporting Rule) to foreign reporting companies and foreign beneficial owners.
Continue Reading FinCEN Issues Interim Final Rule Exempting Domestic Companies and US Beneficial Owners From Reporting Requirements
The Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) located in 30 ZIP codes across California and Texas to, among other things, report and maintain records of cash transactions exceeding $200 (up to $10,000), and to verify the identity of persons presenting such transactions
Continue Reading Effective April 14: FinCEN GTO Requires MSBs Along US Southwest Border to Report Transactions in Currency of More than $200