Advisers, it’s time to prepare! As of September 4, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has adopted a rule that will deem certain investment advisers, including ERAs, as “financial institutions” and require implementation of … Read More
On March 29, 2021, the U.S. Securities and Exchange Commission (“SEC”) Division of Examinations (“EXAMS”) issued a Risk Alert citing frequent shortcomings found in compliance reviews of Anti-Money Laundering (AML) reporting at broker-dealer and mutual fund firms. Find the Risk … Read More
On August 10, 2020, the Securities and Exchange Commission (“SEC”) announced that Interactive Brokers, LLC (“IB” or the “Firm”) had agreed to pay $11.5 million in fines for failure to file Suspicious Activity Reports (“SARs”) in conjunction with trading micro-cap … Read More
We live in a world filled with bad actors who consistently attempt to take advantage of flaws and weaknesses in our financial systems, often to the detriment of the law-abiding majority. When these efforts reach a grand scale in the form … Read More
On August 25, 2015, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury (“Treasury”), proposed a rule that would “prescribe minimum standards for anti-money laundering programs (“AML”) to be established by investment advisers.” This rule would … Read More
Over the past year, there has been an increased focus on Broker-Dealer Anti-Money Laundering (“AML”) programs. Last month, Kevin Goodman, National Associate Director of the Broker-Dealer Examination Program in the Office of Compliance Inspections and Examinations (“OCIE”), spoke at the … Read More
Core Compliance℠ featured in NSCP’s Currents, the April 2015 Special Reprint edition. In this article, we go in depth in an article detailing the current landscape of anti-money laundering. He reviews the regulations, the duties of investment advisers, industry trends, … Read More
Anti-money laundering (AML) regulation – currently applying only to broker-dealers – may soon affect independent advisers under a new proposal being currently drafted by the Financial Crimes Enforcement Network (FinCEN). First set forth as a proposed rule in 2003 and … Read More