On the heels of Executive Order 14178, the President’s Working Group on Digital Asset Markets (Working Group) has released its comprehensive report, “Strengthening American Leadership in Digital Financial Technology” (the...more
The first piece of major US federal legislation in the global digital assets space was signed into law on July 18, 2025, by President Trump.1 Declared by President Trump as positioning the United States to be the “crypto...more
On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date for certain investment advisers to implement anti-money...more
7/24/2025
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Investment Management ,
Regulatory Requirements ,
Rulemaking Process ,
Suspicious Activity Reports (SARs)
On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) and the US Attorney’s Office for the Southern District of Texas announced the first declination of prosecution for an acquirer that...more
On June 9, 2025, US Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (Guidelines), instructing prosecutors...more
On May 27, 2025, Senators Sheldon Whitehouse (D-RI) and Charles E. Grassley (R-IA) submitted a comment to US Treasury Secretary Scott Bessent expressing strong opposition to the Financial Crime Enforcement Network’s Interim...more
On May 12, 2025, the US Department of Justice’s (DOJ) Criminal Division issued a memorandum titled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime (the Memo) to all Criminal Division personnel. The...more
5/19/2025
/ Corporate Crimes ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
New Guidance ,
Self-Reporting ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On May 8, the Financial Industry Regulatory Authority (FINRA) published a blog announcing that it intends to modify the heightened supervision plans (HSPs) imposed as part of certain broker-dealers’ settlements with the US...more
On May 5, 2025, the US House of Representatives Financial Services Committee and Agriculture Committee released a draft bill that would shift oversight of most digital assets from the Securities and Exchange Commission (SEC)...more
5/8/2025
/ Blockchain ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Oversight ,
Securities Regulation ,
Technology ,
Trump Administration
On April 1, 2025, the Texas Association for Money Service Businesses filed a lawsuit in San Antonio federal court challenging the recent Geographic Targeting Order (GTO) applicable to money services businesses (MSBs) located...more
The final judicial barrier to the Financial Crimes Enforcement Network’s enforcement of the Corporate Transparency Act’s beneficial ownership information (BOI) reporting requirements has been lifted.
The Corporate...more
President Trump’s February 10, 2025 Executive Order pausing Foreign Corrupt Practices Act (FCPA) enforcement and ordering an overhaul of FCPA policy marks a significant shift by the Department of Justice (DOJ), at least in...more
2/13/2025
/ Anti-Corruption ,
Attorney General ,
Bribery ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Trump Administration
On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Time Extensions ,
Vacated
On December 3, 2024, the US District Court in the Eastern District of Texas (the Texas Federal Court) granted a nationwide preliminary injunction in favor of certain small businesses, ruling (1) the Corporate Transparency Act...more
12/17/2024
/ Beneficial Owner ,
Business Ownership ,
Corporate Transparency Act ,
Disclosure Requirements ,
FinCEN ,
Injunctions ,
Popular ,
Preliminary Injunctions ,
Reporting Requirements ,
Small Business ,
Suspended Judgment ,
Unconstitutional Condition
The booklet summarises key financial crime related legal and regulatory changes expected over the next 18 months to 2 years, as well as providing electronic links to key resources.
Key developments:
- US Supreme Court...more
10/3/2024
/ Chevron Deference ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
FBAR ,
Financial Crimes ,
IRS ,
Legislative Agendas ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Reform ,
SCOTUS ,
Whistleblower Protection Policies
Last Monday, the Department of Justice (the DOJ or the Department) announced significant updates to the DOJ Criminal Division’s Evaluation of Corporate Compliance Programs (ECCP). These updates discuss, for the first time,...more
The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more
3/25/2024
/ Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Extortion ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On March 1, 2024, the United States District Court for the Northern District of Alabama found that the Corporate Transparency Act (CTA) is unconstitutional because it exceeds Congress’ legislative power. The 53-page opinion...more
“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more
1/25/2024
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Pilot Programs ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
As of January 10, 2024, US securities exchanges may list Bitcoin ETFs for trading. Cryptocurrency enthusiasts hope this decision signals a broader adoption of cryptocurrency in the United States. Perhaps it does, but...more
The Financial Crimes Enforcement Network (FinCEN) issued the Beneficial Ownership Information Access and Safeguards Rule (Access Rule) establishing the framework for access to and protection of beneficial ownership...more
1/8/2024
/ Beneficial Owner ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Foreign Entities ,
Gramm-Leach-Blilely Act ,
Policies and Procedures ,
Regulatory Oversight ,
Reporting Requirements ,
U.S. Treasury
On October 4, 2023, US Deputy Attorney General (DAG) Lisa Monaco announced that the US Department of Justice (DOJ) is adopting a new Mergers & Acquisitions Safe Harbor Policy, incentivizing companies to voluntarily disclose...more
10/10/2023
/ Acquisitions ,
Antitrust Division ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Mergers ,
Policies and Procedures ,
Safe Harbors ,
Voluntary Disclosure
The Financial Crimes Enforcement Network (FinCEN) has proposed extending the deadline for certain companies to comply with the Corporate Transparency Act (CTA) and report their beneficial ownership information (BOI) from 30...more
On August 28, 2023, the Securities and Exchange Commission (SEC) announced a settled enforcement action against Impact Theory LLC (Impact Theory) for the unregistered sale of non-fungible tokens (NFTs) that the SEC determined...more
On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more