Betsy T. Voter

Jun 26, 2024 | mondaq.com | Senators Introduce Bill |Betsy T. Voter

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances. Earlier this year, the Financial Crimes Enforcement Network ("FinCEN") issued a proposed rule that would bring SEC-registered investment advisers and Exempt Reporting Advisers ("Covered Advisers") within the scope of key U.S. anti-money laundering ("AML") rules (see our prior alert for more information).

Jun 24, 2024 | lexology.com | Iqan E. Fadaei |Betsy T. Voter

Earlier this year, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would bring SEC-registered investment advisers and Exempt Reporting Advisers (“Covered Advisers”) within the scope of key U.S. anti-money laundering (“AML”) rules (see our prior alert for more information). However, that proposal did not require Covered Advisers to adopt and maintain a Customer Identification Program (“CIP”), since any such rule must be adopted alongside the SEC.

May 18, 2024 | mondaq.com | Betsy T. Voter

If you've ever wondered whether the SEC's Division of Enforcement is active, here is a recap of 4 kinds of enforcement actions the SEC has been bringing recently. The SEC is continuing its sweep of RIAs for compliance with the Marketing Rule, having settled actions against several RIAs in the last 6 months for violations of the rule's performance advertising provisions.

Apr 16, 2024 | mondaq.com | Betsy T. Voter |Iqan E. Fadaei

For many years, key U.S. anti-money laundering laws (in particular, rules under the Bank Secrecy Act) have applied to financial institutions other than investment advisers. This may soon change. On February 13, 2024, the Financial Crimes Enforcement Network ("FinCEN") proposed a rule (the "Proposed Rule") that would extend various anti-money laundering ("AML") and countering of terrorism financing ("CFT") obligations to investment advisers.

Sep 23, 2023 | lexology.com | Kevin C. Timken |Iqan E. Fadaei |Betsy T. Voter

On September 12, the SEC filed charges against Virtu for allegedly misleading customers about the existence and adequacy of information barriers between its customer execution and proprietary trading businesses. The SEC alleges that Virtu failed to safeguard material nonpublic information generated from customer orders that it routed and executed.