News and Insights

"With Precautions, AI Can Help With Suspicious Activity Filings," Law360

As artificial intelligence takes the world by storm, potential use cases proliferate by the day. Compliance professionals are looking closely at the tasks that AI technology may be able to perform, supplement and improve in their compliance processes.In this article, we examine the considerations around the use of AI in one important area in the regulatory and enforcement environment affecting financial services businesses — suspicious activity reports, or SARs.The filing of SARs, and failures r...READ MORE

Fintech Focus: Investment Advisers Join Ranks of Financial Institutions Subject to the Bank Secrecy Act

Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network (“FinCEN”) rule imposing anti-money-laundering obligations on a broader range of investment advisers may place them in an unfamiliar and heavily regulated territory. Below, we briefly recap the requirements of the rule we first outlined in its proposed form in our February 2024...READ MORE

“How Transaction Lookbacks Can Guide Fintech Companies,” Law360 

Financial regulatory enforcement continues to be active this year, with approximately 18 anti-money laundering actions against financial institutions across federal regulators including the Financial Crimes Enforcement Network, the Federal Deposit Insurance Corp., the Federal Reserve Board, the Office of the Comptroller of the Currency, and the New York State Department of Financial Services, one of the most aggressive state regulators.With these actions, regulators are looking closely at custom...READ MORE

It’s April, Do You Know Where Your California Digital Assets License Is?

California's new licensing regime for digital financial asset businesses is no longer on the horizon, it is here. The California Department of Financial Protection and Innovation (DFPI) opened its application portal last month, and the July 1, 2026 compliance deadline is now less than three months away. For companies that anticipate serving California residents with covered digital financial assets services, there is a significant advantage to having a license application in by July 1....READ MORE

California’s Digital Asset Regulation Gets Closer to Final

Under California’s new Digital Financial Assets Law, or DFAL, all entities engaging in “digital financial asset business activity” in the state must be licensed—or have a pending application—by July 1, 2026. On September 29, 2025, the California Department of Financial Protection and Innovation (DFPI) issued a Notice of Modification to Text of Proposed Regulation (Modification Notice) amending the previously issued April 4, 2025 Notice of Proposed Rulemaking....READ MORE

The SEC Expands Its Cybersecurity Oversight by Adopting Regulation S-P Amendments

Earlier this month, approximately one year after releasing its proposed amendments to Regulation S-P, the SEC announced the adoption of final amendments to Regulation S-P, expanding the information protected, the policies and procedures required, and the entities covered by the rules.  Covered financial institutions—including any broker-dealer, investment company, registered investment adviser, or transfer agent—will now be required to establish and implement a reasonable incident response progr...READ MORE

Associate Gina Shabana Moderates Panel Hosted by the Association for Women in Cryptocurrency

On August 27 Associate Gina Shabana moderated an Association for Women in Cryptocurrency panel about the global crypto landscape. The panel discussed the shifting dynamics of US crypto and the practical implications of navigating an environment where regulatory intent is clear but specific rules are still emerging....READ MORE