On Feb. 1, 2021, the Financial Regulatory Authority (FINRA) released its 2021 Report on FINRA’s Examination and Risk Monitoring Program (Report), in which it identifies its areas of examination focus for FINRA member firms (Firms) in 2021. The Report replaces the prior format for examination focus, the Risk Monitoring and Examination Program Priorities Letter. In the introduction to the Report, FINRA acknowledges the ongoing COVID-19 pandemic, its regulatory notice in response, and the challenges…

On Jan. 13, 2021, the Division of Investment Management staff (Staff) of the Securities and Exchange Commission (Commission) issued a no-action letter advising that it would not recommend enforcement action to the Commission under Section 17(f) of the Investment Company Act of 1940 (1940 Act), and paragraphs (b)-(f) of Rule 17f-2 thereunder, if certain registered management investment companies or series thereof (Funds), or their directors or officers, if the Funds, acting as self-custodians, maintain certain…

On Jan. 1, 2021, the U.S. Senate overwhelmingly voted (81-13) to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 20211, passing into law legislation that includes – as Division F – the Anti-Money Laundering Act of 2020 (AML Act).2 This GT Alert provides an overview of the important themes and significant provisions of the AML Act. Continue reading the full GT Alert, “The Anti-Money Laundering Act of 2020: Congress …

On Jan. 1, 2021, the U.S. Senate joined the House in voting to override President Trump’s veto of the National Defense Authorization Act of 2021 (NDAA), which includes several new anti-money laundering (AML) provisions that may be of keen interest to dealers and other participants in the art and antiquities markets. The legislation comes on the heels of a lengthy report issued by the Senate’s Permanent Subcommittee on Investigation in mid-2020, entitled The Art Industry …

On Dec. 21, 2020, Congress approved H.R. 133, referred to as the “Consolidated Appropriations Act, 2021” (the Act). The legislation, signed into law by President Trump on Dec. 27, 2020, enhances and expands certain provisions of the Coronavirus Aid, Relief, and Economic Security Act of 2020 (the CARES Act) (H.R. 748) and changes the Paycheck Protection Program (PPP) administered by the U.S. Department of the Treasury’s Small Business Administration (SBA) by (i) authorizing additional liquidity…

On Dec. 18, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) that would impose on banks and money services businesses (MSBs) new recordkeeping, reporting, and identity verification requirements for certain transactions involving convertible virtual currency (CVC) and digital assets with legal tender status (LTDA) held in “unhosted wallets,” i.e., wallets not hosted by a financial institution, or “otherwise covered wallets,” i.e., wallets held at a financial…

The National Association of Insurance Commissioners (NAIC) Fall 2020 National Meeting was held virtually on Dec. 3-4 and Dec. 7-9. Greenberg Traurig attended many of the sessions, and we are pleased provide you with summaries of some of the discussions and actions that took place during the national meeting through the following link: GT Recap | NAIC Fall 2020 National Meeting. If you have any questions, please contact Fred Karlinsky or Rich Fidei.…