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In Anti-Corruption

United States: America first — A recasting of DOJ FCPA enforcement policy in the name of national security

by , , , , , , , and 8 Mins Read

The new DOJ FCPA enforcement policy emphasizes US national security and business interests, moving away from solely prosecuting bribery of foreign officials. The focus will be on bribes involving Transnational Criminal Organizations (TCOs), cartels, and those impacting US competitiveness or national security. Routine, locally accepted business practices are deprioritized. The DOJ will exercise discretion to determine if conduct genuinely impacts US interests, leaving other cases to the SEC or foreign regulators. This creates a more nuanced and unpredictable enforcement environment, with clarity expected only as enforcement patterns emerge.

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In AML & Financial Services Regulatory

Venezuela: The National Superintendence of Securities (SUNAVAL) amends rules on Money Laundering and Terrorist Financing Administration

by , , and 8 Mins Read

The National Superintendence of Securities (SUNAVAL) issued Administrative Ruling No. 251 on 27 March 2025, amending the Rules Regarding the Administration and Control of Risks Related to the Crimes of Money Laundering, Financing of Terrorism, Financing of the Proliferation of Weapons of Mass Destruction and Other Illicit Activities, Applicable to Entities Obligated by the National Superintendence of Securities. The Ruling establishes the parameters that entities acting in the securities market should follow and includes a new regulatory regime for money laundering, financing of terrorism, financing of the proliferation of weapons of mass destruction and other illicit activities. The Ruling became effective on 27 March 2025.

In AML & Financial Services Regulatory

South Africa: Coin vs. Capital – Cryptocurrency is not subject to exchange control

by and 7 Mins Read

In a landmark ruling, the Pretoria High Court in Standard Bank v South African Reserve Bank ruled that cryptocurrencies do not constitute “capital” under South Africa’s Exchange Control Regulations. This means crypto assets are not subject to the country’s strict exchange control regime, offering long-awaited clarity for the crypto industry. While this judgment removes the need for SARB approval to export crypto, the relief may be temporary, as future legislative amendments could reassert regulatory oversight. For now, the decision marks a significant shift in how digital assets are treated under South African financial law.

In AML & Financial Services Regulatory

Australia: ASIC consults on greater public transparency of firm-level reportable situations and complaints data

by , , and 4 Mins Read

On 10 April 2025, the Australian Securities and Investments Commission (ASIC) released Consultation Paper 383 ‘Reportable situations and internal dispute resolution data publication’. Through the Consultation Paper, ASIC has proposed publication of data on Reportable Situations (RS) and Internal Dispute Resolution (IDR), respectively, across two separate interactive dashboards.
RS data is proposed to be published annually, by the end of October each year. IDR data will be published biannually.

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In AML & Financial Services Regulatory

Singapore: MAS consults on proposed revisions to remove exemptions under the financial advertisement regulations

by and 3 Mins Read

On 3 May 2025, the Monetary Authority of Singapore (MAS) issued a consultation paper proposing to remove the current exclusions under the Financial Advisers Regulations and the Securities and Futures (Licensing and Conduct of Business) Regulations (SF(LCB)R) that exempt certain financial institutions from complying with advertising regulations.
This proposal is part of MAS’s broader initiative to enhance market conduct standards, following its 2023 Consultation Paper on Enhancing Safeguards for Proper Conduct of Digital Prospecting and Marketing Activities.

In AML & Financial Services Regulatory

Spain: The new version of the UNE 19601 Standard on Management System for Criminal Compliance has been published

by 3 Mins Read

On 24 April 2025, the revised version of UNE 19601 Standard on Management System for Criminal Compliance was published, replacing the previous version from 2017. UNE 19601 is the reference standard in Spain for implementing a criminal compliance management system and it covers the requirements of the Spanish Penal Code as well as international standards in the field.
The general approach of the initial version is maintained, although modifications have been introduced to adapt it to regulatory changes (primarily, those in the Spanish Penal Code and whistleblowing management standards) and international standards of recent years (such as ISO 37301:2021 or ISO 37002:2021).

In Cybersecurity, Data and Tech

Luxembourg: CSSF aligns with DORA – Key updates on ICT and outsourcing regulations

by , and 4 Mins Read

On 9 April 2025, the Commission de Surveillance du Secteur Financier issued several new circulars related to information and communication technologies risk management and the use of ICT third parties, aiming to align existing circulars and practices with the Digital Operational Resilience Act.

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In AML & Financial Services Regulatory

Argentina: Foreign exchange deregulation continues — repatriation of nonresident investments

by and 1 Min Read

The Central Bank of the Argentine Republic continues its policy of foreign exchange deregulation. This time, through Communication “A” 8230, changes are introduced to the regime for the payment of financial debts with related companies, the repatriation of nonresident investments, and the reduction of minimum holding periods for certain financial investments.

In AML & Financial Services Regulatory

Hong Kong: HKMA and SFC’s guidance on Staking of Virtual Assets

by , and 6 Mins Read

On 7 April 2025, the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) issued guidance for authorized institutions (and subsidiaries of locally incorporated authorized institutions) and SFC-licensed virtual asset trading platforms respectively, who are interested in providing Staking Services. The guidance outlines the regulatory framework and expected standards for providing Staking Services.
On the same day, the SFC revised its “Circular on SFC-authorized funds with exposure to virtual assets” issued on 22 December 2023 to facilitate SFC-authorized virtual asset funds (SFC-authorized VA Funds) which wish to engage in staking and other virtual asset-related activities.

In Corporate Compliance

United States: Enforcement of CTA and BOI reporting rule suspended against US companies and citizens

by 2 Mins Read

Over the past week there have been two significant announcements by US Financial Crimes Enforcement Network and the US Department of the Treasury with respect to the filing of beneficial ownership information (BOI) reports under the Corporate Transparency Act (CTA). Based on these announcements, foreign reporting companies should technically continue complying with the BOI requirements, though there will be no consequences for failing to do so until new regulations are issued. As to domestic reporting companies, there should not be any enforcement of the CTA against such companies or consequences if such companies fail to file BOI reports.

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