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1 month ago | 
jdsupra.com | Joel Cohen |Robert J. DeNault |Ladan Fazlollahi Stewart
May 14, 2025
Joel Cohen, Robert DeNault, Ladan Stewart
White & Case LLP
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In recent months, the U.S. Securities and Exchange Commission has signaled a shift in its approach to applications to lift administrative bars that restrict participation in the securities industry.
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Jan 29, 2025 | 
jdsupra.com | Joel Cohen |Claudette Druehl |Jason Ho
The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures.1 As we outlined in our recent client alert, investment advisers will be required by the Financial Crimes Enforcement Network ("FinCEN") to implement an AML program by January 1, 2026. This SEC action does not shed new light on the scope of SEC jurisdiction over AML.
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Oct 22, 2024 | 
jdsupra.com | Joel Cohen |Robert J. DeNault |Marietou Diouf
October 22, 2024
Joel Cohen, Robert DeNault, Marietou Diouf
White & Case LLP
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On October 10, TD Bank pleaded guilty to violations of the Bank Secrecy Act and conspiracy to commit money laundering.
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Oct 7, 2024 | 
jdsupra.com | Joel Cohen |Marietou Diouf |Courtney Andrews
Over the past year, the Department of Justice ("DOJ") has warned that it will seek stiffer sentences for offenses made significantly more dangerous by the misuse of artificial intelligence ("AI") and has asked the US Sentencing Commission to revise the US Federal Sentencing Guidelines to include an AI-specific sentencing enhancement.
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Sep 27, 2024 | 
jdsupra.com | Joel Cohen |Clare Connellan |Taylor Pullins
September 27, 2024 Joel Cohen, Clare Connellan, Taylor Pullins White & Case LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: An accelerating focus on doing business responsibly will force changes to wide-ranging aspects of business operations and strategy Societal expectations of businesses have shifted fundamentally over the past five years. These new expectations for how businesses relate to people and the planet will be...
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Sep 17, 2024 | 
jdsupra.com | Joel Cohen |Robert J. DeNault |Marietou Diouf
September 17, 2024 Joel Cohen, Robert DeNault, Marietou Diouf, Claudette Druehl, Tami Stark, Pratin Vallabhaneni White & Case LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment advisers that have existed for...
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Aug 7, 2024 | 
jdsupra.com | Joel Cohen |Marietou Diouf |David Lim
In early 2024, we published alerts on separate sets of remarks from Department of Justice ("DOJ") Deputy Attorney General Lisa Monaco warning that the DOJ would be seeking stiffer sentences for offenses made significantly more dangerous by the misuse of artificial intelligence ("AI").1 Deputy Attorney General Monaco specifically warned that the DOJ would seek reforms to the existing sentencing enhancements if it determined that they do not adequately address the harms associated with the...
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Jul 2, 2024 | 
jdsupra.com | Joel Cohen |Robert J. DeNault |Marietou Diouf
On June 27, 2024, the Supreme Court ruled in SEC v. Jarkesy that when the Securities and Exchange Commission (SEC) seeks civil penalties from defendants for securities fraud, the Seventh Amendment requires it to bring the action in a court of law where the defendant is entitled to a trial by jury. The 6-3 decision ends the SEC’s long-running use of in-house tribunals led by Administrative Law Judges (ALJs) to adjudicate fraud actions.
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Jun 6, 2024 | 
jdsupra.com | Joel Cohen |Tami Stark |Ladan Fazlollahi Stewart
In February 2024, we published an alert discussing the significant benefits of prompt self-reporting and cooperation during a US Securities and Exchange Commission ("SEC") investigation. This past week, during his keynote address at the Securities Enforcement Forum West 2024 conference, the Director of the Division of Enforcement ("Enforcement Director"), Gurbir S.
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May 21, 2024 | 
jdsupra.com | Joel Cohen |Robert J. DeNault |Marietou Diouf
May 21, 2024 Joel Cohen, Robert DeNault, Marietou Diouf, Claudette Druehl, Tami Stark, Pratin Vallabhaneni White & Case LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule supplements a proposal in February to...
