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
As the COVID-19 situation continues to evolve, market volatility, workplace disruptions and a shuttering of everyday life are becoming increasingly commonplace. While the 2021 LIBOR phase-out may not seem top
Continue Reading All Systems Go? LIBOR Transition Efforts During the COVID-19 Pandemic
On July 22, 2019, the federal bank regulatory agencies and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “Agencies”), issued a Joint Statement on Risk-Focused Bank
Continue Reading Joint Statement Emphasizes Risk-Focused Approach to Examinations of Banks’ BSA/AML Compliance Programs
On August 2, 2017, United States Senators Marco Rubio (R-FL) and Ron Wyden (D-OR) jointly introduced Senate Bill 1717, entitled the “Corporate Transparency Act of 2017” (the “Act”). The Act
Continue Reading New Bill Introduced in the U.S. Senate to Require the Disclosure of Ultimate Beneficial Owners of Corporations and LLCs Formed or Registered in the United States
Today, the SEC announced the adoption of amendments to several rules under the Investment Advisers Act of 1940 and to Form ADV, the investment adviser registration and reporting form.
Continue Reading New ADV Rule
As robo-advisers continue to grow in popularity with investors, especially millennial investors, at least one regulator is taking a closer look. On July 14, 2016, Massachusetts Secretary of the Commonwealth
Continue Reading Massachusetts Offers Policy Guidance on Investment Advisers’ Use of Robo-Advisers
Sarao, Coscia, and now the Berkshire Power Company, each charged with crimes – spoofing, fraud, false information – relating to commodity trading. Commodity traders likely have incorporated into their compliance
Continue Reading Coscia Gets 3 Years in Prison: The Criminalization of Trading Commodities?
In connection with the Press Release announcing a Rule Proposal regarding adoption of written business continuity and transition plans by SEC-registered investment advisers (see our blog post on the topic),
Continue Reading SEC IM Guidance Update – Investment Company Business Continuity Plans
On June 23, 2016 the Office of the Comptroller of the Currency (OCC) hosted the Forum on Responsible Innovation in the Federal Banking System in Washington, D.C. Hundreds of industry
Continue Reading OCC Forum on Responsible Innovation
During recent months the SEC has made a number of announcements regarding its efforts to enhance and expand its oversight and inspections of registered investment companies and investment advisers. Of
Continue Reading SEC Acts to Enhance Oversight of Funds and Advisers