On January 20, the Financial Conduct Authority (FCA) published a letter to the CEOs of UK-based alternative investment firms to outline the FCA’s view of the key risks of harm to the customers or markets in which such firms operate (the Letter). The FCA defines alternative investment firms as firms that predominately manage alternative investment vehicles (such as hedge funds or private equity vehicles), or manage alternative assets directly, or provide advice on such vehicles or assets.
Continue Reading FCA Publishes Dear CEO Letter for UK Alternative Investment Firms

On October 25, the Financial Conduct Authority (FCA) published a new webpage setting out important information for UK cryptoasset businesses in the context of anti-money laundering (AML) and counter terrorist financing (CFT).

As announced in July 2019, the FCA will be the AML/CFT regulator for certain cryptoasset activities starting January 10, 2020. However, the scope of ‘cryptoasset activities’ is still to be determined by Her Majesty’s Treasury (HMT), whose consultation on the matter closed on June 10.
Continue Reading FCA Publishes Cryptoasset AML/CFT Webpage

On October 18, the Financial Action Task Force (FATF) published its updated list of jurisdictions that have strategic anti-money laundering (AML) and counter-terrorist financing (CTF) deficiencies for which they have developed an action plan with the FATF. The FATF updates this list three times a year, the last update being in June 2019.
Continue Reading FATF Updates List of AML/CFT Deficient Jurisdictions

On October 18, the Financial Conduct Authority (FCA) published a letter giving guidance on the distinction between suspicious activity reports (SARs) and suspicious transaction and order reports (STORs). The letter was sent in response to a request by UK Finance, a trade association, following a meeting of the ‘SARs Collaboration Working Group.’
Continue Reading FCA Publishes SAR and STOR Guidance

On October 11, the leaders of the Commodity Futures Trading Commission (CFTC), the Financial Crimes Enforcement Network (FinCEN), and the Securities and Exchange Commission (collectively, the Agencies) issued a joint statement reminding persons engaged in activities involving digital assets of their anti-money laundering (AML) and countering the financing of terrorism (CFT) obligations under the Bank Secrecy Act of 1970 (BSA).
Continue Reading CFTC, FinCEN, and SEC Issue Joint Statement on Activities Involving Digital Assets

On September 25, the Joint Money Laundering Steering Group (JMLSG) announced on its website that HM Treasury has approved revisions to three chapters in Part II of the JMLSG’s anti-money laundering and counter-terrorist financing sectoral guidance.

The amended guidance relates to credit unions (section 4), asset finance (section 12) and brokerage services to funds (sector

On July 24, the European Commission (EC) published a suite of documents assessing the current anti-money laundering (AML) and counter-terrorist financing (CTF) framework in operation in the European Union (EU).

Although each document is addressed to the European Parliament and the Council of the EU, the EC states that it believes that these documents will support the EU and national authorities to better address money laundering and terrorist financing risks. It notes that some improvements can be made quickly at an operational level, and the EC will continue to support EU member states in this, while also reflecting on how to address the remaining structural challenges.
Continue Reading European Commission Publishes Assessment of EU AML and CTF

On March 12, the National Futures Association (NFA) published Notice I-19-08, notifying Member futures commission merchants (FCMs) and introducing brokers (IBs) of a March 8 advisory published by the Financial Crimes Enforcement Network (FinCEN) regarding updates to the Financial Action Task Force’s list of jurisdictions with deficiencies regarding anti-money laundering and combating the financing of