Topic
Record Keeping
223 published works
Financial Services Observer
US Treasury Extends Recordkeeping Requirement for Economic Sanctions Compliance to 10 Years
By Kara M. Bombach, Marina Olman-Pal, Miranda R. Carnes, Cyril T. Brennan, Sonali Dohale
On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule (Final Rule) extending the recordkeeping requirement for compliance with U.S.…
Financial Services Observer
Effective April 14: FinCEN GTO Requires MSBs Along US Southwest Border to Report Transactions in Currency of More than $200
By Marina Olman-Pal, Shane Foster, W. H. Langley Perry, Jr.
The Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) located in 30 ZIP codes across California and Texas to, among other…
Nonprofit Law Prof Blog
Did A U.S. Nonprofit Loose Covid-19?
When the shit hits the fan, every nonprofit involved better have good records. That is the lesson from HHS' debarment of EcoHealth, an exempt research organization, from further NIH funding.…
Compliance Building
Investment Advisers Hit with Texting Fines
Twelve firms were hit with fines for off-channel communications. I’ve been waiting for these cases to come out. A couple of these firms have publicly traded securities and there have…
The Securities Law Blog
Twelve Firms to Pay More Than $63 Million Combined to Settle SEC’s Charges for Recordkeeping Failures
The Securities and Exchange Commission today announced charges against nine investment advisers and three broker-dealers for failures by the firms and their personnel to maintain and preserve electronic communications, in…
Roberts Disability Law Blog
Second Circuit Upholds Dismissal of ERISA Record-Keeping Fees Lawsuit
In Boyette v. Montefiore Med. Ctr., No. 24-1279-CV, 2025 WL 48108 (2d Cir. Jan. 8, 2025), decided by Circuit Judges Kearse, Raggi, and Lohier, Jr., the court upheld the dismissal…
Bright Law Blog
Record-keeping obligations for Australian financial services licensees when giving personal advice
ASIC has registered ASIC Corporations (Record-Keeping Requirements for Australian Financial Services Licensees when Giving Personal Advice) Instrument 2024/508 which inserts a new section 912G in the Corporations Act. Unless extended,…
Consumer Finance Monitor
FDIC board approves NPRM that would increase recordkeeping for custodial accounts
By Ronald K. Vaske, Kristen E. Larson, Ballard CFS Group
On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those…
The Securities Law Blog
SEC Charges 12 Municipal Advisors With Recordkeeping Violations
The Securities and Exchange Commission today announced charges against 12 municipal advisors for failures by the firms and their personnel to maintain and preserve certain electronic communications. The firms agreed…
SmarTrade
OFAC Publishes Interim Final Rule Extending Recordkeeping Requirement to 10 Years
By Scott E. Diamond**, Francesca M.S. Guerrero, Samir D. Varma, Aaron C. Mandelbaum
On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Interim Final Rule to amend its Reporting, Procedures and Penalties Regulations under 31…