Venable attorneys produce periodic alerts and newsletters covering a variety of topics and practice areas. For your convenience, we have assembled below a collection of the latest alerts and newsletters from January 2016.
The Coming SEC Sweep in Hedge Funds, a Primer on Investor Qualification, and More in the January 2016 Edition of Fund Forum
There was much that happened in 2015 that provides guidance to funds and investors in 2016. For example, in this issue we discuss the anticipated SEC commencement of presence examinations for hedge funds and analyze four Letters of Acceptance, Waiver and Consent issued by FINRA. We also provide a primer on Investor Qualification and clarify key terms important to a fund's fundraising efforts. Finally, we briefly review the Martin Shkreli case.
FinCEN Takes First AML Action against Dealer in Precious Metals, Stones, and Jewels
The Financial Crimes Enforcement Network (FinCEN) announced its first action against a dealer in precious metals, precious stones, and jewels. The enforcement action included a $200,000 civil money penalty against the business, the owner, and the compliance officer for willfully violating federal anti-money laundering (AML) laws. In addition to the fine, the company has agreed to several undertakings to extend through 2020, including retaining an external auditor, providing a comprehensive annual report to FinCEN outlining the implementation of its improved AML program, and annually providing a copy of, and certifying attendance and testing results of, the company's AML training program.
U.S. Lifts Certain Sanctions on Iran, Implementing Historic Nuclear Deal: What is the Impact for U.S. and Non-U.S. Persons?
On January 16, 2016 (Implementation Day), the International Atomic Energy Agency certified that Iran had implemented measures to curb its nuclear program. As a result, the United States and the European Union (EU) lifted a number of sanctions as envisioned by the Joint Comprehensive Plan of Action. While the EU lifted most of its sanctions, the U.S. provided for modest relief in the form of lifting "secondary" sanctions directed toward non-U.S. persons and de-listing certain Iranian persons and companies.
Venable Launches Brushstrokes, a Monthly e-Newsletter Reporting on All Facets of the Art World
Members of Venable's Art Law Group provide highlights and analysis surrounding recent developments in the art world from both a national and an international perspective. Brushstrokes is designed to deliver news and information across the gamut of business and legal matters, including contract negotiations, tax issues, estate planning, charitable giving, entity formation, and import/export issues just for start.