In February 2025, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a report outlining its assessment of the sanctions-related threats posed to the UK by firms operating in the UK’s financial services sector. As to be expected, the report focuses on the risks associated with transactions since February 24, 2022, when Russia invaded Ukraine … Continue Reading
Non-financial misconduct (“NFM”) within the financial sector has posed significant challenges for the U.K. Financial Conduct Authority (“FCA”) for several years. The FCA handbook prescribes that regulated firms must assess and certify to the FCA, at least annually, that senior individuals and those performing regulated activities meet the relevant standards of fitness and propriety to … Continue Reading
In this article, we summarize the trends that have emerged from enforcement actions published between 2022 and the present day by the Dubai Financial Services Authority (the “DFSA”).… Continue Reading
The Cayman Islands, a British overseas territory, has long been recognized as one of the world’s leading providers of institutionally focused financial services and a preferred destination for the structuring and domiciling of sophisticated and specialized financial services products, particularly investment funds. However, for a number of reasons, the inherent risks to the Cayman Islands’ … Continue Reading
In September, a class action lawsuit (Mannacio v. Discover Financial Services, et al., No. 23-cv-06788 (N.D. Ill.)) was filed against Discover Financial Services (“Discover”) alleging Discover and certain current and/or former executives violated the Securities Exchange Act of 1934. Specifically, the class action complaint alleged that the defendants made false and/or misleading statements and/or failed … Continue Reading
The United Arab Emirates (“UAE”) has long been at the forefront of embracing technological and financial innovation. For example, Dubai has emerged as a global hub for virtual assets (“VAs”) and cryptocurrencies. Earlier this year, the Dubai Virtual Assets Regulatory Authority (“VARA”) adopted its first Virtual Assets and Related Activities Regulations 2023 (the “Regulations”), along … Continue Reading
Perhaps the signature initiative of the Department of Justice’s Civil Rights Division under the current Administration has been its Combatting Redlining Initiative. By “redlining,” the Department means that a lender has avoided providing access to home mortgage loans to homeowners and prospective homeowners in majority-minority census tracts, in violation of the Fair Housing and Equal … Continue Reading
On October 19, 2020, the Financial Crimes Enforcement Network (FinCEN) released its assessment of a $60 million civil monetary penalty against the operator of two cryptocurrency “mixers” for violations of the Bank Secrecy Act (“BSA”).[1] The action marks the first effort by FinCEN to target the use of these “mixers” to facilitate money laundering and … Continue Reading
