Recent News
Update: Customer Due Diligence Rule Now in Effect
Despite some last minute pushback, the Financial Crimes Enforcment Network’s (FinCEN) long-anticipated Customer Due Diligence Requirements for Financial Institutions (CDD Rule) became fully effective on May 11th. The CDD Rule, which was proposed initially in August 2014, amends Bank Secrecy Act regulations to clarify and strengthen customer due diligence obligations for financial institutions. FINRA stated that the purpose behind the CDD Rule is “to improve financial transparency and prevent criminals and terrorists from misusing companies to disguise their illicit activities and launder their ill-gotten gains.”
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Update: DOL Issues Non-Enforcement Policy on Fiduciary Rule
Following the recent federal court decision to vacate the fiduciary duty rule, the Department of Labor released a Field Assistance Bulletin setting forth a temporary enforcement policy applicable to investment advice fiduciaries. The new policy is intended to address uncertainty about fiduciary obligations formerly required by the DOL rule, or under the Best Interest Contract Exemption, the Principal Transactions Exemption and certain amended prohibited transaction exemptions (collectively PTEs).
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Join us at the NYC Bar Association’s White Collar Crime Kickoff Reception
Join Bates as we co-sponsor the NYC Bar Association’s White Collar Crime kickoff reception, Tuesday, May 8, 2018 at 6:30 PM. Meet Bates CEO Jennifer Stout and Directors Sejal Patel and Beth Finkle to learn about our Financial Crimes Practice.
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