BRAEDEN ANDERSON

Welcome to Anderson Insights.

We provide authoritative analysis on securities and commodities regulation, SEC and FINRA enforcement, and legal developments affecting crypto, digital assets, fintech, and financial services, authored by Braeden Anderson.

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K. Braeden Anderson 4/11/26 K. Braeden Anderson 4/11/26

FinCEN Proposes Sweeping Changes to AML/CFT Compliance Structure

FinCEN’s 2026 AML/CFT proposal reshapes compliance by focusing on risk-based programs, effectiveness, and reduced regulatory burden. Attorney Braeden Anderson provides a detailed legal analysis of what it means for financial institutions.

K. Braeden Anderson 7/22/25 K. Braeden Anderson 7/22/25

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”).

K. Braeden Anderson 1/29/25 K. Braeden Anderson 1/29/25

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.

K. Braeden Anderson 9/27/24 K. Braeden Anderson 9/27/24

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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Braeden Anderson

K. Braeden Anderson serves as a Partner at Gesmer Updegrove LLP, where he leads the firm’s Blockchain & Digital Assets and Securities Enforcement & Investigations practices. He also chairs Mackrell International’s Blockchain & Digital Assets Group and its Securities Enforcement & Investigations Group.

Named to Best Lawyers: Ones to Watch® in America (2025) for Financial Services Regulation Law and Securities Regulation, Mr. Anderson has built a national reputation as a securities regulatory and enforcement attorney operating at the intersection of traditional finance and emerging technologies. His practice focuses on advising financial institutions, fintech companies, investment advisers (including robo-advisors), broker-dealers, trading platforms, and digital asset companies in complex regulatory, enforcement, and compliance matters before the SEC, CFTC, FINRA, DOJ, and state regulators.

Within the digital asset and blockchain space, Mr. Anderson regularly counsels clients on issues involving market structure, tokenization, robo-advisor and broker-dealer registration, custody frameworks, AML and KYC obligations, and secondary trading considerations for regulated assets. His work spans both established financial institutions and early-stage ventures, helping clients operate within rapidly evolving regulatory environments with precision and strategic clarity.

Mr. Anderson also represents professional athletes and sports organizations in connection with regulatory and investigative matters requiring careful handling and discretion.

Prior to joining Gesmer, Mr. Anderson founded a Washington, D.C.-based law firm. He previously served as Assistant General Counsel at Robinhood Markets, Inc. (HOOD), where he advised on significant regulatory and enforcement matters. Earlier in his career, he practiced at Kirkland & Ellis LLP and Sidley Austin LLP in New York and Washington, D.C., representing clients in matters involving major federal enforcement authorities and providing regulatory advice on complex financial matters.

Mr. Anderson is an active contributor to the national conversation on securities and digital asset regulation. He publishes a widely followed weekly newsletter that has reached millions of legal and financial professionals and produces video content on YouTube for an audience of over 160,000 subscribers. He is also the editor of this legal publication, Anderson Insights, where he provides in-depth analysis for regulators, in-house counsel, and compliance professionals.

Mr. Anderson is also the creator of The Long Game with Braeden Anderson, a new digital series on YouTube exploring the intersection of golf, discipline, and high-performance thinking, featuring match-play conversations with legal executives and business leaders.

He was recently recognized as the most-read fintech thought leader in the United States in Mondaq’s Spring 2025 Thought Leadership Awards.