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On April 20, 2026, the SEC and CFTC proposed amendments to Form PF, the confidential reporting form filed by SEC-registered advisers to private funds, including those registered with the ...
In this issue, we discuss a recent enforcement action involving fraud and registration charges against three venture capital fund managers and their owner.
On April 21, 2026, a divided panel of the Tenth Circuit affirmed the District Court’s ruling in Liberty Global Inc. v. United States, holding that the economic substance doctrine applie...
The OCC, Federal Reserve, and FDIC released updated guidance on model risk management, which rescinds and supersedes prior guidance to establish a more principles-based approach. Our visu...
OFAC’s recent “Guidance on Sham Transactions and Sanctions Evasion” suggests heightened due diligence obligations and erodes the “bright line” distinction between ownership and ...
FinCEN and OFAC have taken steps to implement the AML/CFT and sanctions compliance obligations under the GENIUS Act, the most notable of which include compliance requirements applicable t...
With the implementation of the UK’s new prospectus regime on January 19, 2026, five years of debate, consultations and reform to improve the competitiveness of the UK capital markets re...
Following the April 2026 proposed rules from FinCEN, OCC, FDIC and NCUA, the Federal Reserve has released its own proposed AML/CFT program rule. The proposed rules largely reorganize the ...
This visual memorandum provides a summary and overview of the Department of the Treasury’s proposed rules that would update requirements for anti-money laundering and countering the fin...