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Client Alert March 21, 2024

New U.S. Rules For Investment Advisors Could Bring Aggressive Scrutiny on Non-U.S. Individuals

  • New rules proposed by the U.S. Financial Crimes Enforcement Network (FinCEN) would extend U.S. anti-money laundering program requirements to investment advisors.
  • This could become the latest move by U.S. authorities to scrutinize the assets and transactions of ultra-high-net-worth individuals, including those outside the U.S.
  • At-risk individuals and their advisors should take proactive steps to protect their legitimate interests.

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Client Alert November 30, 2022

Two Ways the Art World Could Get Swept into the Sanctions Orbit

  • Global sanctions targeting, among others, Russian individuals and entities are layering on top of anti-money laundering measures.
  • These will directly impact players in the art market, raising their litigation and enforcement risks.
  • We explain two particular triggers stakeholders should be aware of.

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