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
Welcome to the inaugural issue of Greenberg Traurig’s Financial Services Insights. The impact of Coronavirus Disease 2019 (COVID-19) has been both unexpected and devastating. As the economic fallout spreads, financial
On Thursday, Aug. 20 at 11 a.m. EST, join GT Shareholders Carl Fornaris and Oscar Stephens for a complimentary webinar on the status of the phaseout of LIBOR, current trends
Continue Reading Webinar – Aug. 20: LIBOR Phaseout – Preparing for the Beginning of the End
On June 22, 2020, in Liu v. SEC, the Supreme Court affirmed in an 8-1 ruling that the Securities and Exchange Commission may continue to pursue disgorgement awards under
Continue Reading SEC Disgorgement Lives to See Another Day After Supreme Court’s Liu v. SEC Ruling
On June 3, 2020, Congress passed the PPP Flexibility Act to loosen requirements for loan forgiveness for CARES Act Paycheck Protection Program (PPP) borrowers. The new forgiveness rules will allow
Continue Reading Congress Passes the PPP Flexibility Act
As another sign of the times, but arguably quite apt given the subject matter, the Consensus Blockchain Conference convened virtually in 2020, with Financial Crimes Enforcement Network (FinCEN) Director Ken
Continue Reading FinCEN Director Confirms Enforcement Focus on Virtual Currency AML Compliance
On March 21, 2019, in Whitaker v. Wedbush Securities, an Illinois appellate court for the first time addressed the liability of a futures commission merchant (FCM) or broker-dealer (BD)
Continue Reading When Can Futures Commission Merchants and Broker-Dealers Be Deemed Banks?
The U.K.’s Criminal Finances Act 2017 provides law enforcement with new powers to obtain orders to freeze bank accounts and apply for forfeiture orders, permanently depriving the account holder of
Continue Reading Prove It or Lose It! Part III: A Step Too Far? Account Freezing Orders & Account Forfeiture Orders in the UK
Unexplained Wealth Orders (UWOs) extend the powers available to UK law enforcement authorities under the Proceeds of Crime Act 2002 (POCA), enabling investigators to ask people who are holding assets,
Continue Reading Prove It or Lose It! Parts I and II: Unexplained Wealth Orders and Civil Recovery Orders in the United Kingdom