Michael A. Mancusi

Arnold & Porter Discusses Final FinCEN Rules for Investment Advisers Under Bank Secrecy Act

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On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule to add “investment adviser” to the definition of “financial institution” under the regulations implementing the Bank Secrecy Act (BSA). The final rule defines the term “investment …

Arnold & Porter explains New York Takes Lead on Anti-Terrorism and Anti-Money Laundering Enforcement by Proposing Criminal Liability for Compliance Officers

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On December 1, 2015, the New York Department of Financial Services (the DFS) released a proposed rule that would require certain New York-regulated financial institutions (Regulated Institutions) to comply with enhanced anti-terrorism and anti-money laundering (AML) requirements and subject chief …

Arnold & Porter explains US Policy Developments in FinTech and Payments Systems: Federal Reserve Establishes Tasks Forces of Faster Payments and Secure Payments

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FinTech businesses focused on payments systems and foreign exchange have witnessed an explosion of demand in recent years. As these payment systems services continue to gain mainstream acceptance, financial regulators in the US are increasingly interested in monitoring and, as …