Securities Enforcement. Investigations. Regulation.

Independent analysis of the laws, regulations, investigations, and enforcement actions shaping modern financial markets.

BRAEDEN ANDERSON

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GESMER UPDEGROVE

RECOGNITION AND LEADERSHIP

Braeden is one of the top securities lawyers in the country and was recognized by Best Lawyers: Ones to Watch® in America in the Financial Services Regulation Law and Securities Regulation categories. This honor is awarded to only the top 2% of attorneys in the United States and is based on a comprehensive peer-review survey.

Braeden helped lead Gesmer Updegrove to recognition in The Legal 500 United States for Corporate Investigations & White Collar Crime, Tier 3, and Finance: Fintech, Tier 4.

Braeden is active in the U.S. securities enforcement community through Securities Docket, where he has served on the 2025 and 2026 Advisory Boards and contributed video commentary through the Weekly Update.

Braeden was named the #1 United States author in FinTech in Mondaq’s Spring 2025 Thought Leadership Awards, reflecting the national reach and influence of his writing on fintech, securities regulation, and digital asset policy.

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Treasury Postpones Effective Date of Investment Adviser AML Rule; Signals Broader Reassessment of Regulatory Framework

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced today its intent to postpone the effective date of its final rule imposing anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) requirements on investment advisers (the “IA AML Rule”).

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KuCoin’s $297M Settlement Marks a Turning Point in Crypto Compliance

Crypto exchange KuCoin has agreed to pay $297 million and pled guilty to operating an unlicensed money transmitting business, following allegations of widespread anti-money laundering (AML) failures and the facilitation of over $5 billion in illicit transactions. This significant development underscores the growing scrutiny of cryptocurrency platforms by U.S. regulators and law enforcement.

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New FinCEN AML Rule Brings Heightened Scrutiny to Registered and Exempt Reporting Investment Advisers

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) finalized a rule that imposes new Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) program requirements on registered investment advisers (RIAs) and exempt reporting advisers (ERAs). For the first time, these advisers will be formally recognized as “financial institutions” under the Bank Secrecy Act (BSA), and thus subject to its AML/CFT regulations. The new rule will go into effect on January 1, 2026, signaling a significant shift for both RIAs and ERAs, who will need to implement comprehensive compliance programs to meet these requirements.

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