On November 21, the Financial Industry Regulatory Authority issued Regulatory Notice 17-40, which provides member firms guidance as it relates to compliance with Rule 3310 in light of the Financial Crimes Enforcement Network’s (FinCEN) adoption of Customer Due Diligence Requirements (CDD Rule).
Continue Reading FINRA Releases Guidance In Light of FinCEN Customer Due Diligence Requirements

On April 10, the National Futures Association (NFA) published Notice I-17-09, which notified member futures commission merchants (FCMs) and introducing brokers (IBs) of an April 5 advisory published by the Financial Crimes Enforcement Network (FinCEN), regarding updates to the Financial Action Task Force’s list of jurisdictions with strategic anti-money laundering and combating the financing of

On September 14, the National Futures Association (NFA) published Notice I-16-19, which notified member futures commission merchants (FCMs) and introducing brokers (IBs) of a September 7 advisory published by the Financial Crimes Enforcement Network (FinCEN) regarding updates to the Financial Action Task Force’s list of jurisdictions with strategic anti-money laundering and combating the financing of

The Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would require registered investment advisers to establish anti-money laundering programs and file suspicious activity reports with FinCEN in certain circumstances. FinCEN also is proposing to include investment advisers in the general definition of “financial institution” under the Bank Secrecy Act of 1970 (BSA). This change would subject investment advisers to multiple BSA requirements, including the obligation to file Currency Transaction Reports and to keep records relating to the transmittal of funds.
Continue Reading Anti-Money Laundering Program and Suspicious Activity Report Filing for Investment Advisers

On July 20, the Financial Crimes Enforcement Network (FinCEN) issued an advisory announcing that the Financial Action Task Force (FATF) has updated its list of jurisdictions with anti-money laundering and counter-terrorist financing (AML/CFT) deficiencies. In connection with this update, the National Futures Association (NFA) issued a notice reminding futures commission merchants and introducing brokers to

The US Attorney’s Office in the Northern District of California recently settled an enforcement action against Ripple Labs Inc., a Delaware corporation providing virtual currency exchange services. According to the settlement agreement, Ripple Labs was not registered with the Financial Crimes Enforcement Network (FinCEN) as a money services business (MSB) pursuant to the Bank Secrecy Act of 1970 while engaged in currency trading, and lacked required anti-money laundering controls.
Continue Reading Department of Justice Settles Virtual Currency Enforcement Action

On March 16, the Financial Crimes Enforcement Network (FinCEN) issued an advisory announcing that the Financial Action Task Force (FATF) has updated its list of jurisdictions that have strategic deficiencies in their anti-money laundering (AML) and counter-terrorist financing (CFT) regimes. 

Specifically, FATF has noted that: (1) Indonesia has been removed from FAFT’s list that calls for enhanced due diligence and has been moved to the FATF’s list of jurisdictions having AML/CFT deficiencies, and (2) Albania, Cambodia, Kuwait, Namibia, Nicaragua, Pakistan and Zimbabwe have been removed from the FATF listing and monitoring process. 
Continue Reading FinCEN Updates List of Jurisdictions with AML/CFT Deficiencies