AML/KYC – Global Investment Law Watch

FinCEN Proposes AML Requirements on Registered Investment Advisers (including Exempt Reporting Advisers)

Feb 16 2024

By: Richard F. Kerr, Jennifer L. Klass, and Annabelle H. North

On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) that would impose anti-money laundering (AML) and counter-terrorist financing (CFT) requirements on Securities and Exchange Commission-registered investment advisers (the SEC, and such investment advisers, RIAs) and exempt reporting advisers (ERAs). FinCEN previously made similar rule proposals in both 2003 and 2015, which were never finalized.

$2 Billion Money Laundering Case Threatens Singapore’s Reputation

Oct 20 2023

By: Edward Bennett and Ke Jia Lim

Singapore, known for its fiercely guarded reputation as a global financial hub and growing asset management centre, is currently entangled in one of the most substantial money laundering scandals globally, with a staggering S$2.8 billion (US$2 billion) in seized assets. Ten suspects, originally from China but residing in Singapore, face money laundering charges linked to scams and illegal online gambling.

Europe: UK’s FCA Challenges Firms to Improve Sanction Screening Processes

Sep 25 2023

By: Joseph Skilton, Michael Ruck, Rosie Naylor

The FCA has assessed and reported on the sanctions controls of over 90 financial service firms from a range of sectors including wealth management.

Europe: Systemically important outsourced service providers, eg cloud services, to be identified and regulated in the UK

Jul 08 2022

By: Kai Zhang

In an 8 June 2022 policy statement, the UK Government proposes a specific regime for supervising “critical” service providers to the financial services industry. This is to address concentration risk as many regulated firms rely on a few large service providers whose failure could potentially threaten the stability of, or confidence in, the UK’s financial system. The Government observes that in 2020 over 65% of UK regulated firms used the same four cloud providers for cloud infrastructure services.

Europe: Pressure Grows on UK Regulated Firms to Manage Cryptoasset-Related Risk

Mar 28 2022

By: Kai Zhang

On 24 March 2022, the FCA issued a notice reminding firms with cryptoassets exposures of its expectations on certain risks. The key themes are:

Avoiding consumer confusion: As cryptoassets are generally not regulated, the FCA expects firms involved in cryptoassets to ensure that consumers understand the distinction between their regulated business and unregulated business (i.e. relating to cryptoassets).

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