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

Proxy advisory firms (Proxy Firms) have long provided institutional investors advice and recommendations with respect to management and shareholder proxy proposals. In recent years, the Securities and Exchange Commission (SEC)
Continue Reading The SEC’s 2020 Amendments to Proxy Rules and Supplemental Guidance to Investment Advisers on Proxy Voting Responsibilities

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

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