Alerts
FinCEN, OFAC, the UN, EU and UK Issue Advisories, Freeze Orders, Other Measures Related to Libya, Egypt and Tunisia
March 17, 2011
As a result of the recent unrest in Libya, Egypt and Tunisia, the U.S. Financial Crimes Enforcement Network ("FinCEN") has issued a series of advisories to remind financial institutions of their obligations under the USA PATRIOT Act to apply enhanced scrutiny for private bank accounts held by or on behalf of senior foreign political figures and to monitor transactions and file Suspicious Activity Reports involving transfers that may represent misappropriated or diverted state assets, proceeds of bribery or other illegal payments, or other public corruption proceeds. The FinCEN advisories draw particular attention to the fact that the recent instability in the area creates a heightened risk that senior foreign political figures (also known as politically exposed persons) in the Libyan, Egyptian and Tunisian governments may attempt to move misappropriated government funds out of their respective countries.
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The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]
Alerts
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Alerts
The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]
Alerts
On March 1, 2024, New York Governor Kathy Hochul signed into law an amended version of the New York LLC Transparency Act (“NYLTA”),[1] requiring certain limited liability companies (“LLCs”) formed or authorized to do business in New York (each, a “NY Reporting Company”) to file a beneficial ownership information (“BOI”) report with the NY Department of State (“NY DOS”). Each NY Reporting Company will be required to disclose on its BOI report identifying information pertaining to each individual who directly or indirectly exercises substantial control or owns or controls 25 percent or more of the ownership interests of a NY Reporting Company (each, a “Beneficial Owner”) and the individuals involved in the NY Reporting Company’s formation or registration to do business in New York (each, an “Applicant”). Information reported to NY DOS will be maintained in a private database not accessible to the public. The NYLTA goes into effect on Jan. 1, 2026 and requires the NY DOS to promulgate regulations implementing the legislation.
Alerts
The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]