Meagan Griffin

🚀 The SEC and CFTC just signed a new MOU on regulatory harmonization, and looks like much more than a good press release. tl;dr the agencies are committing to joint rulemakings, coordinated exams, shared data and a "minimum effective dose" regulatory philosophy. Why does this matter? The US is the only major capital market that splits financial regulation between two agencies. After decades of duplicative registrations & conflicting rules we now have a Joint Harmonization Initiative with dedicated staff from both agencies to actually fix it. The guiding principles are where the real signal is. The MOU explicitly commits both agencies to "reject a turf war mentality" and states that they "jointly recognize the foundational importance of fair notice to market participants and not regulating through enforcement." That second part is doing a LOT of work. On crypto specifically, the agencies commit to "closely coordinating and cooperating to remove obstacles" to lawful introduction of novel derivative and crypto asset products. That's the industry unlock: not "we won't block things" but "we'll work to clear the path." Combined w/ the fit-for-purpose framework language, this is the clearest joint signal yet on crypto regulatory posture. The MOU also opens the door to "alternative compliance frameworks" and "appropriately tailored and regulated 'super-apps'" — for anyone watching the M&A trends toward full-stack tradfi + crypto platforms, this is the regulatory infrastructure they need. The operational commitments matter too. For dually registered firms (broker-dealers that are also FCMs, RIAs that are also CPOs) the agencies commit to joint exam planning, shared findings and harmonized risk assessments. On enforcement, they'll consult at the outset of any investigation w/ overlapping jurisdiction and coordinate before issuing Wells notices. Less duplication, fewer conflicting obligations. I've mentioned before that strong coordination between the CFTC and SEC is a massive unlock, not just for crypto but for every firm that touches both securities and derivatives. This MOU puts the philosophy in writing w/ actual coordination mechanisms behind it. Chairs Selig and Atkins deserve a ton of credit for enabling this. Now comes execution. Link to full MOU & press release: https://lnkd.in/eQpWWA4N

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Your investor client is closing on a cash deal through an LLC next week. There is a federal report now required. As of March 1st, 2026. Neither you nor they probably know about it yet. Here's what changed: FinCEN — the U.S. Treasury's Financial Crimes Enforcement Network — has a new rule in effect called the Residential Real Estate Reporting Rule. In plain English: If a residential property closes in cash, through an LLC, corporation, or trust — someone in that transaction must now file a federal report disclosing the actual human beings behind that entity. Not the LLC name. Not the registered agent. The real people. Government ID numbers. Addresses. Who it hits in South Florida: → All-cash residential purchases (1-4 family, condos, co-ops, certain vacant land) → Where the buyer is an LLC, corp, or trust → Not financed through a bank with AML requirements That is most of your investor cash deals. That is most of your foreign national buyers closing through entities. That is the portfolio client who just went under contract last Tuesday. Who files the report: FinCEN uses a "reporting cascade" — a hierarchy that works down the closing chain. In almost every transaction, it lands on the title company or settlement agent. That is us. We are set up. We are filing. Your investor clients are probably not aware this exists. What happens if no report gets filed: Civil penalties up to $1,394 per day. Criminal liability for willful violations. No grace period. No "we didn't know." The rule is not coming. It is not pending. It went into effect ten days ago. If you have cash-deal clients closing through LLCs or trusts in Broward, Dade, or Palm Beach: Tell them before their next closing. Not after. 📌 Save this. Send it to every investor in your database today. 📞 (954) 789-4503 | titlenowfl.com — Tahir Noohani, Esq. Title Now LLC #FinCEN #FloridaRealEstate #InvestorAlert #TitleNow #CashDeals #SouthFlorida #RealEstateLaw #KnowBeforeYouClose

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NinjaTrader, a well-known Chicago-based futures commission merchant, recently came under significant regulatory scrutiny after the National Futures Association (NFA) imposed a $250,000 fine on the firm. The action highlights persistent weaknesses in NinjaTrader’s anti-money laundering (AML) program and supervisory controls—two areas considered critical by regulators in the futures and derivatives sector. The NFA, a self-regulatory organization overseeing U.S. derivatives markets, cited NinjaTrader for not adhering to the standards set out in its Compliance Rules. Specifically, the Business Conduct Committee’s formal Complaint referenced violations of NFA Compliance Rule 2-9 and the related Interpretive Notice 9045, which require members to implement effective AML programs and to supervise all aspects of their business diligently. In this article: - Anti-Money Laundering Compliance Failures at NinjaTrader - NFA’s Regulatory Role and the Importance of Supervision - The Evolution of AML Requirements in the U.S. Futures Market - Consequences for Compliance Failures in the Futures Sector - Strengthening AML and Supervision: What Firms Can Learn - Conclusion: The Ongoing Challenge of AML Compliance A comment, a repost, or even better a quick click to the article on the website itself means a lot to FinCrime Central—and who knows, you might find something interesting! Read the full article on FinCrime Central:  https://lnkd.in/e5nbp7ex The image above is AI-generated.

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Just cleared the National Institute of Securities Markets (NISM) AML and CFT Provisions in Securities Markets Certification. This wasn't about adding another certificate to the wall. It was about deepening the technical foundation for work we're already doing at Coinshell. Over the past year, we've been increasingly involved in AML policy drafting, compliance framework design, and forensic accounting engagements across some interesting sectors: → 𝗪𝗲𝗯𝟯 & 𝗖𝗿𝘆𝗽𝘁𝗼 companies navigating PMLA compliance and FIU-IND reporting requirements → GIFT City entities setting up AML/CFT frameworks aligned with IFSCA regulations → 𝗕𝗮𝗻𝗸𝘀 𝗮𝗻𝗱 𝗡𝗕𝗙𝗖𝘀 requiring transaction monitoring system reviews and STR/CTR filing support → 𝗘𝘅𝗽𝗼𝗿𝘁 𝗯𝘂𝘀𝗶𝗻𝗲𝘀𝘀𝗲𝘀 dealing with FEMA compliance and banking KYC escalations What I've observed: Most compliance failures aren't due to lack of intent. They happen because policies exist on paper but aren't operationally integrated into daily workflows. That's where our approach differs. We don't just draft AML manuals , we build systems that actually work. From customer due diligence procedures to suspicious transaction identification, from employee training to regulatory audit preparation. The certification formalises what the work has taught me. But the real learning continues with every client engagement. If you're building in 𝗿𝗲𝗴𝘂𝗹𝗮𝘁𝗲𝗱 𝘀𝗲𝗰𝘁𝗼𝗿𝘀 ( 𝗪𝗲𝗯𝟯 , 𝗙𝗶𝗻𝘁𝗲𝗰𝗵 , 𝗦𝗲𝗰𝘂𝗿𝗶𝘁𝗶𝗲𝘀 𝗲𝘁𝗰 ) and need someone who understands both the letter and the spirit of AML/CFT compliance - Let's connect. #AML #Compliance #CFT #Web3Compliance #GIFTCity #FinancialCrime #ForensicAccounting #coinshell

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Check out the key developments shaping consumer financial services this week in the Sheppard Mullin Consumer Finance & Fintech Blog: ▪️ The D.C. Circuit cleared the way for CFPB layoffs, reversing a lower court block ▪️ CFPB closed its BNPL firearms financing investigation, citing political bias concerns ▪️ California DFPI ordered a mortgage lender to pay $2.3M for per diem interest overcharges ▪️ The Federal Reserve ended its Novel Activities Supervision Program for crypto and fintech oversight ▪️ CFPB reopened its Section 1033 rulemaking on personal financial data rights Explore the full set of updates here: https://lnkd.in/dGwAJnDK #Consumer #Finance #Fintech #CFPB #DFPI #Crypto #OpenBanking #SheppardMullin

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The recently-published SEC regulatory/deregulatory agenda includes two items of note: - Amendments to the Custody Rule - Customer Identification Programs for RIAs and ERAs TBD whether the Custody Rule amendments will just address custody of crypto assets or the custody of funds/securities more broadly, but IMO the Custody Rule is ripe for an overall refresh. The Customer Identification Program (CIP) rule traces its roots all the way back to the 2001 USA PATRIOT Act and is the counterpart to the AML/CFT rule that was recently punted to 2028. The AML/CFT rule and CIP rule should effectively be a package deal, so I'd be surprised if one was ultimately passed w/out the other. -----Resources----- 🔖 SEC regulatory/deregulatory agenda: https://lnkd.in/gWZaeH_A 🔖 SEC Chairman Paul Atkins statement: https://lnkd.in/g4SYy5RW

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Everyone’s talking about AI risk, but the real ticking time bomb might be in stablecoin integrations and digital asset partnerships 💣💣 Right now, community banks and credit unions are sprinting toward “innovation” by exploring digital assets and stablecoin rails, but have most of them mapped the risk surface beyond a few optimistic slide decks? What happens if a liquidity event hits? Or if a stablecoin partner gets hacked? Or if customers suddenly realize they don’t have the same protections they’d expect from a traditional bank deposit? We’re already seeing the GENIUS Act shape conversations about AI accountability, but digital assets are quietly becoming the next compliance frontier. The intersection of AI, payments, and stablecoin infrastructure is creating a web of dependencies few are prepared to manage. At RayCor Consulting, LLC, we’ve seen this firsthand through our work with stablecoin issuers and digital asset platforms. The ones thinking ahead are building adaptable oversight programs now, not waiting for regulators to tell them how. If you need assistance with implementing, understanding, or training on GENIUS, we've got you covered ✅ If your institution is exploring AI or digital assets, what’s your biggest blind spot right now: risk mapping, vendor diligence, or governance structure? Curious what others are seeing. (h/t Dana Lawrence for sparking this conversation 🎩; loved your thoughts on risk and GENIUS Act compliance, and I look forward to continuing the convo!) #Compliance #DigitalAssets #Stablecoins #GENIUSAct #RiskManagement #Fintech

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An interesting turn of events. A couple of weeks ago I posted about JPMorgan Chase's decision to charge fees for access to customer bank account information. This was on the heels of the CFPB itself asking the court to vacate the Bureau's own rule that would require banks to share data freely upon consumer request. Amid growing backlash on JPMorgan Chase's decision, the CFPB today asked the court to stay the action. It appears the CFPB wants to maintain the Rule and to revise same after further examination. Given the rapid pace of technological innovation, particularly the emergence of stablecoins as a parallel financial infrastructure, it is a reasonable and necessary approach to reexamine the CFPB rule. The financial sector is evolving beyond traditional intermediaries and there is a reshaping of how consumers access and move funds, raising questions that require further analysis and input from key stakeholders. #fintech #openbanking #JPMorganChase

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