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Ryan DiSantis

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Ryan’s background as an assistant U.S. attorney for more than a decade, where he prosecuted cases involving the FCPA, extortion, securities fraud, tax fraud, and more, equips him with a unique perspective, and his frequent representation of the U.S. in numerous jury trials and appeals showcases his litigation prowess.

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  • DOJ has reportedly directed all 93 U.S. Attorneys’ Offices to maintain a minimum of 25 open matters per prosecutor, a metrics-driven mandate that has drawn criticism as unworkable for complex white-collar and national security cases. 
  • The quota could incentivize earlier and more aggressive initiation of investigations, increasing the likelihood of grand jury subpoenas,
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FinCEN has issued an order granting exceptive relief from the longstanding requirement that covered financial institutions (CFIs) identify and verify the beneficial owners of legal entity customers every time a new account is opened. CFIs now need to collect and verify beneficial ownership information once per customer and then update it only when risk or new information warrants. While CFIs must still comply with all other Bank Secrecy Act (BSA) and anti-money laundering and counter-financing terrorism (AML/CFT) obligations, the new order represents an easing of the requirements established by FinCEN’s Customer Due Diligence regulation (the 2016 CDD rule) regarding the diligence CFIs must perform on legal entity customers as part of AML/CFT programs. Companies should consider whether it makes sense to maintain stricter past compliance practices or revise current policies to fit the new rules based on an individualized risk assessment.

You Are Invited: SEC Enforcement Priorities Webinar

Thursday, February 6, 2025 | 12:00 – 1:00 pm ET

Please join Troutman Pepper Locke for a discussion hosted by the Atlanta Bar Association with Regional Securities and Exchange Commission Directors Nicholas Grippo (Philadelphia Regional Office) and Nekia Jones (Atlanta Regional Office) on the SEC’s 2025 enforcement and examination priorities.