Compliance Headlines
THE ENVIRONMENT
More developments in legislation to watch. Senators from leading states – NY and Wyoming – team up to propose allegedly reasonable new oversight over blockchain projects.
Projected “Robust Enforcement” of Bank Secrecy Act. Cryptocurrency Companies to remain a focus of CFTC and Justice Dept. enforcement.
SEC and Other Enforcement Actions
SEC settles the first enforcement action concerning ESG disclosures against a mutual fund adviser for alleged misstatements and omissions in its Fund disclosures concerning incorporation of ESG factors into the investment process.
A settlement was reached with NVIDIA Corporation, a public company, for alleged failure to disclose on its 10Q that crypto mining was a significant element of its revenue.
Smoothing Performance Numbers and Manual Spreadsheet leads to multi-billion securities fraud, manipulation and criminal liability. SEC Charges Allianz Global Investors the firm agreed to pay more than $1 billion to the SEC and over $5 billion to victims as restitution.
Sanctions liability is criminal liability. See this important case for blockchain projects. In Re: Criminal Complaint [Underseal]involves the use of a payment platforms allegedly designed and advertised to evade U.S. sanctions, through ostensibly untraceable virtual currency transactions.
YOUR COMPLIANCE & RISK PROGRAM
A good reminder – it’s not what happens, but how a team reacts. The South Korea regulators appear to be taking a common approach – broad investigation – focusing on intent of those who knew about problems…Terra Investigation
