On Monday, April 25, 2022, the U.S. Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced a settlement with Toll Holdings Limited (“Toll”), an Australian freight forwarding and logistics company, with respect to Toll’s originations and/or receipt “of payments through the U.S.» Read More
On Jan. 1, 2021, Congress enacted, over President Trump’s veto, the National Defense Authorization Act, a 4500-page behemoth that in its midst contained the Anti-Money Laundering Act of 2020 (“AMLA”). I attempted to give some overview of this legislation in my Jan.» Read More
On Tuesday, November 30, 2021, the U.S. Securities and Exchange Commission (“SEC”) issued a Press Release concerning its most recent update to the list of entities NOT registered with the SEC “that use misleading information to solicit primarily non-US investors.” That update adds 82 soliciting entities, 8 “impersonators of genuine firms,” and 1 “bogus” regulator.» Read More
On Friday, July 9, 2021, the U.S. Securities and Exchange Commission (“SEC”) charged Apostolos Trovias, a Greek national, with selling (from 2016 until early in 2021) what he termed “insider trading tips,” including prerelease earnings reports, on the Dark Web. Trovias, according to the SEC Complaint, operated using the “pseudonymous avatar ‘The Bull’.”» Read More
On December 22, 2020, the U.S. Securities and Exchange Commission (“SEC”) unanimously adopted a NEW Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (the ”IA Act”), replacing old Rule 206(4)-1 originally adopted in 1961, and also eliminating Rule 206(4)-3 originally adopted in 1979.» Read More
