Posts Categorized: Uncategorized

FinCEN Extends Program to Identify Beneficial Owners of Real Estate Entities to November

The Financial Crimes Enforcement Enforcement Network (“FinCEN”) of the U.S. Treasury has extended to November its program to require title insurance agencies in certain cities to collect and report to it the beneficial owners of legal entities used to purchase real estate.  The “Geographic Targeting Order” applies to acquisitions of residential real estate in certain… Read more »

FINRA Establishes Office of Financial Innovation

In a press release dated April 24, 2019, the Financial Industry Regulatory Authority (“FINRA”) announced that it had established the Office of Financial Innovation.  The office is focused on financial technology, otherwise known as FinTech.  Haimera Workie, originally a graduate of MIT and Harvard and now a Senior Director at FINRA,  has been named it… Read more »

New Provisions of Delaware LLC Law

In July 2018, the Delaware Limited Liability Company (“LLC”) law was amended to allow registered series and division of LLCs.  Delaware LLCs could be divided into series previously, but among other things the series were not considered “registered organizations” for purposes of Title 9 of the Uniform Commercial Code.  LLC series can now be registered by… Read more »

FINRA Seeks Notification of Broker-Dealer Digital Asset Activity

On July 6, 2018, the Financial Industry Regulatory Authority (“FINRA”) issued Regulatory Notice 18-20 encouraging broker-dealers regulated by it to notify it if the broker-dealer or an affiliate currently engages, or intends to engage, in any activities related to digital assets.  FINRA says that this will assist it in monitoring developments in the digital asset… Read more »

New FCPA Enforcement Policy

On November 29, 2017, the U.S. Department of Justice (the “DOJ”) issued an update to its U.S. Attorney’s Manual to adopt a new Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (the “Policy”).  Under the Policy, credit will be given to certain self-reporting by companies (in the form of declination to prosecute or lower fines) or… Read more »

U.K. Anti-Money Laundering Regulation Updated

The United Kingdom has published a near final regulation, the Money Laundering and Transfer of Funds (Information on the Payer) Regulations 2017 (the “Regulation”) under the E.U. Fourth Money Laundering Directive, to replace the Money Laundering Regulations 2007.  The Regulation is due to go into effect on June 26, 2017, although it may be delayed.  Under the… Read more »