During a summit celebrating its one-year anniversary, the Disruptive Technology Strike Force provided updates on its efforts to prevent authoritarian regimes and hostile nation-states from acquiring critical technologies.

Read on for details about a new expansion of the effort, recent prosecutions and the group’s continued focus on cases involving theft of trade secrets and export…

The Bank Secrecy Act (“BSA”) establishes program, recordkeeping, and reporting requirements for certain financial institutions to combat and detect money laundering, terrorist financing, and other illicit activities.  On February 13, 2024, FinCEN proposed new rules which expand the scope of the BSA to include certain investment advisers, which currently are not subject to any federal or state regulations regarding anti-money laundering (“AML”) or counter-financing of terrorism (“CFT”) compliance.  FinCEN also published a fact sheet on the proposed rules that provides a helpful summary of the key provisions.

Rule Regarding Access to Beneficial Ownership Information Takes Effect

On February 21, 2024, FinCEN published a Small Entity Compliance Guide to aid in compliance with the Corporate Transparency Act’s (“CTA”) Beneficial Ownership Information (“BOI”) Access and Safeguards Rule (“Access Rule”).  The Compliance Guide is called the Small Entity Compliance Guide only because federal law requires that the federal government issue guidance specifically directed at facilitating smaller business’s compliance efforts.  Notwithstanding the title, the Compliance Guide will assist financial institutions (“FIs”) of all sizes with understanding FinCEN’s expectations for access to the BOI database once such access is approved.