On Oct. 23, 2023, FinCEN published an NPRM that identifies international CVC mixing as “a class of transactions of primary money laundering concern,” and finds that imposing additional recordkeeping and
Continue Reading FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing
The Corporate Transparency Act of 2019 (CTA), enacted as part of the Anti-Money Laundering Act of 2020, requires, for the first time, that certain U.S. legal entities and foreign entities
Continue Reading Corporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting Requirements
On Sept. 6, 2023, the Securities and Exchange Commission’s Division of Examinations issued a Risk Alert detailing the Division’s examination selection process for SEC-registered investment advisers (Advisers). The Risk Alert
Continue Reading SEC Risk Alert to Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents
By a 3-2 party-line vote, on Aug. 23, 2023, the Securities and Exchange Commission adopted some of the most significant new rules under the Investment Advisers Act of 1940, as
Continue Reading Private Fund Adviser Rulemaking
On July 26, 2023, the Securities and Exchange Commission (SEC) adopted the long-awaited final rule requiring that public companies disclose information about cybersecurity incidents within four business days of determining
Continue Reading SEC Finalizes Cyber Rules for Public Companies: What You Need to Know
On March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank, Santa Clara, CA (SVB) and appointed the Federal Deposit Insurance Corporation (FDIC) receiver of
Continue Reading The 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties
On April 3, 2023, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a policy statement explaining the prohibition against abusive conduct in consumer financial markets, attempting to bring clarity
Continue Reading CFPB Policy Statement Aims to Clarify Prohibition on Abusive Conduct in Consumer Financial Markets
On Sept. 29, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule, effective Jan. 1, 2024, implementing the beneficial ownership information reporting
Continue Reading Beneficial Ownership Reporting Requirements: FinCEN Issues Final Rule for Implementation of Corporate Transparency Act
On Oct. 7, 2020, the U.S. Securities and Exchange Commission (SEC) held an open meeting and issued a notice proposing a conditional exemption from securities broker-dealer registration under Section 15
Continue Reading SEC Proposes Exemption from Registration for Finders
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