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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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Money Transmitter Licenses 101

If your product accepts value from one person and moves it to another person or location, you may be a money transmitter. That status triggers federal MSB registration and, in most states, a money transmitter license. Read more…

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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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