On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule that will impose new anti-money laundering and countering terrorism financing (AML/CFT) program requirements on registered investment advisers and exempt reporting advisers (collectively, Covered IAs) by, among other things, including Covered IAs within the definition of “financial
United States
DOJ pits whistleblowers versus companies in a race to report criminal misconduct
On August 1, 2024, the US Department of Justice (DOJ) officially rolled out its Corporate Whistleblower Awards Pilot Program. The program is focused on financially incentivizing whistleblowers to report allegations of corporate crime.
Read our alert here.
Global Asset Management Review: Issue 2
In the second issue of Global Asset Management Review, our cross-border team provide market updates followed by a closer look at some of the key issues impacting the asset management sector including:
The DOL’s fiduciary rule put on pause
On July 25, 2024, in the case of Federation of Americans for Consumer Choice, Inc., et al. v. United States Department of Labor, et al., (“Federation of Americans”) the United States District Court for the Eastern District of Texas issued an order staying the effective date of the DOL’s final fiduciary rule (and related amendments…
“Chevron is Overruled” Supreme Court decision upends the era of agency rule
The US Supreme Court’s ruling on the Chevron doctrine in Loper Bright Enterprises v. Raimondo (Loper), will profoundly impact multiple industries regulated by federal agencies that have grown accustomed to being the ultimate arbiter of ambiguous language in their applicable laws, rules and regulations. Those days are over—courts no longer have to defer…
FSB progress report – Enhancing the Resilience of Non-Bank Financial Intermediation
On 22 July 2024, the Financial Stability Board issued a progress report regarding enhancing the resilience of non-bank financial intermediation (NBFI).
The progress report describes recent and ongoing work by the FSB to address systemic risk of NBFI. It sets out the main findings of work over the past year to assess and…
CFPB takes steps to regulate “earned wage access” providers
On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a proposed interpretive rule to regulate offerings in the paycheck advance marketplace. The proposed interpretive rule would deem many paycheck advance products, sometimes marketed as “earned wage advances” or “earned wage access” (EWA) products, as consumer loans subject to the…
FSB report – Stocktake on Nature-related Risks: Supervisory and regulatory approaches and perspectives on financial risk
On 18 July 2024, the Financial Stability Board (FSB) issued a report providing a stocktake of member financial authorities’ initiatives related to the identification and assessment of nature-related financial risks.
The report draws on a survey of participating FSB members and the work done by international organisations on nature-related risks. It summarises current…
The AI adventure – how artificial intelligence may shape the economy and the financial system
On 16 July 2024, the Bank for International Settlements published a speech by Klass Knot (Chair of the Financial Stability Board (FSB) and President of the Netherlands Bank). The speech is dated 11 July 2024 and is entitled The AI adventure – how artificial intelligence may shape the economy and the financial system…
Basel Committee final disclosure framework for banks’ cryptoasset exposures and targeted amendments to its cryptoasset standard
On 17 July 2024, the Basel Committee on Banking Supervision (Basel Committee) published its final disclosure framework for banks’ cryptoasset exposures and targeted amendments to its cryptoasset standard. Both standards have an implementation date of 1 January 2026.
The final disclosure framework (DIS55) is based on the disclosure requirements contained in the final…