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Results: 1-10 of 17

FinCEN’s ANPRM on customer due diligence for financial institutions comments due May 4

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • March 9 2012

On March 5, 2012, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Treasury Department (“Treasury”), issued an advanced notice of proposed rulemaking (“ANPRM”) requesting input from various industries on customer due diligence (“CDD”) requirements for financial institutions

US securities regulators issue guidance on mastersub-account arrangements

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • February 28 2012

U.S. securities regulators have issued a series of alerts and regulatory notices, and have brought several enforcement actions that have focused on mastersub-account relationships

US and international community continue to expand sanctions against Iran

  • Schulte Roth & Zabel LLP
  • -
  • Iran, USA
  • -
  • February 17 2012

On July 1, 2010, President Obama signed into law the Comprehensive Iran Sanctions Accountability, and Divestment Act of 2010 (“CISADA”),1 to protect the security and interests of the United States by helping to prevent Iran from developing nuclear weapons

FinCEN issues final rules and interpretive guidance relating to prepaid access

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • January 6 2012

On July 29, 2011, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, issued a final rule (the “Prepaid Access Rule” or the “Rule”), amending the Bank Secrecy Act (“BSA”) rules relating to prepaid access

FinCEN issues final rules relating to MSB definitions

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • October 26 2011

On July 21, 2011, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued a final rule, revising the regulations regarding money services businesses

Treasury issues notices extending FBAR deadlines for officers and employees of investment advisers and others

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • June 28 2011

The U.S. Department of the Treasury (“Treasury”) has issued guidance with respect to the filing of reports of foreign financial accounts (“FBARs”) by officers and employees of investment advisers and others with different filing deadlines

OFAC issues general license relating to investment funds with Libyan investors

  • Schulte Roth & Zabel LLP
  • -
  • Libya, USA
  • -
  • April 12 2011

On April 8, 2011, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 4 Guidance and General License with Respect to Investment Funds in Which There Is a Blocked Non-Controlling, Minority Interest of the Government of Libya (“General License”

Treasury clarifies FBAR Regulations for private investment funds

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • April 1 2011

On March 28, 2011, the Final Regulations, issued by the Financial Crimes Enforcement Network of the U.S. Department of the Treasury ("Treasury") relating to the filing of Reports of Foreign Bank and Financial Accounts ("FBAR") became effective

SEC extends and modifies its no-action relief for BDs to rely on RIAs for performance of CIP

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • February 24 2011

On Jan. 11, 2011, the Division of Trading and Markets (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”), in consultation with the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, issued a no-action letter in response to a request from the Securities Industry and Financial Markets Association (“SIFMA”) in which it agreed that it would continue not to recommend enforcement action to the Commission under Exchange Act Rule 17a-8 if a broker-dealer relies on a registered investment adviser (“RIA”) to perform some or all of its Customer Identification Program (“CIP”) obligations under Section 326 of the USA PATRIOT Act of 2001 (the “PATRIOT Act”) and 31 C.F.R. 103.122 thereunder (collectively, the “CIP Rule”), subject to certain enumerated conditions

Government launches FCPA inquiry into investments by sovereign wealth funds in U.S. banks and private equity firms

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • January 18 2011

In recent years, the U.S. Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) have stepped up their enforcement of the anti-bribery provisions of the U.S. Foreign Corrupt Practices Act of 1977 (“FCPA”), imposing record criminal fines and civil penalties, such as the $800 million fine in 2008 against Siemens, the German conglomerate