Parties have an additional six weeks to prepare for the impact of FinCEN’s June 25, 2025 orders targeting three Mexican financial institutions.
On August 19, 2025, FinCEN extended the effectiveness date of three orders...more
Introduction The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” or the “Act”) establishes a legal framework for defining, issuing, custodying and managing a specific kind of...more
New and significant prohibitions against financial transactions between U.S. financial institutions and three Mexican financial institutions are set to go into effect in a little over a month on September 4, 2025. In late...more
8/1/2025
/ Banking Sector ,
Banks ,
Borrowers ,
Credit Facilities ,
Financial Institutions ,
FinCEN ,
Fund Managers ,
Lenders ,
Mexico ,
Money Laundering ,
Sanctions
On June 25, 2025, FinCEN announced its first orders under the 2024 FEND Off Fentanyl Act, finding that three Mexican financial institutions—CIBanco S.A. Institución De Banca Multiple (“CIBanco"), Intercam Banco S.A.,...more
7/14/2025
/ Anti-Money Laundering ,
Banks ,
Compliance ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Mexico ,
New Legislation ,
Opioid
On June 25, 2025, FinCEN announced its first orders under the 2024 FEND Off Fentanyl Act, finding that three Mexican financial institutions—CIBanco S.A. Institución De Banca Multiple (“CIBanco"), Intercam Banco S.A.,...more
The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more
6/24/2025
/ Cryptocurrency ,
Digital Assets ,
Digital Currency ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment ,
OCC ,
Payment Systems ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Service Professionals ,
Stablecoins ,
U.S. Treasury
On May 23, 2025, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25, which provides broad authorization for U.S. persons to engage in dealings prohibited under the Syrian Sanctions...more
On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) released a new interim final rule that exempts U.S. entities and U.S. beneficial owners from the reporting requirements of the Corporate Transparency Act...more
On March 2, 2025, the U.S. Treasury Department announced it will not enforce any penalties or fines against U.S. citizens, domestic reporting companies, or beneficial owners of domestic reporting companies under the Corporate...more
3/5/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury
The Corporate Transparency Act’s (CTA) reporting obligations are back in effect after a nationwide court order blocking the CTA’s implementing regulations was stayed on February 17, 2025. Most reporting companies are now...more
2/25/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Disclosure Requirements ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements
On January 23, 2024, the Supreme Court overturned a nationwide injunction enjoining enforcement of the Corporate Transparency Act (“CTA”). However, the implementing regulations of the CTA remain unenforceable due to a...more
The Corporate Transparency Act (“CTA”) is currently unenforceable while the Fifth Circuit considers the federal government’s expedited appeal of a nationwide preliminary injunction that enjoins implementation of the CTA....more
The U.S. Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) granted the federal government’s motion and stayed enforcement of a lower court’s nationwide injunction against enforcement of the Corporate Transparency...more
12/27/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, enjoining the federal government from enforcing the...more
12/17/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, enjoining the federal government from enforcing the...more
On June 28, 2024, The U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (the “Proposed Rule”) that would amend FinCEN’s anti-money laundering (“AML”) program rules for...more
During the week of the G7 Summit, both the U.S. and UK issued a new round of Russia-related sanctions as Russia’s invasion of Ukraine enters its 28th month. On June 12, 2024, the U.S. Department of the Treasury’s Office of...more
6/19/2024
/ Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
G7 ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
UK ,
Ukraine
On March 1, 2024, the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (“CTA”) is unconstitutional. The CTA requires many U.S. entities to disclose their individual beneficial...more
3/25/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Commerce Clause ,
Congressional Authority ,
Constitutional Challenges ,
Corporate Transparency Act ,
FinCEN ,
Motion To Enjoin ,
National Security ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Evasion ,
U.S. Treasury
The U.S., EU and UK have imposed significant new sanctions and are stepping up enforcement against sanctions evaders on the second anniversary of Russia’s full-scale invasion of Ukraine. On February 23, 2024, the U.S....more
2/28/2024
/ Economic Sanctions ,
EU ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Military Conflict ,
Russia ,
Sanction Violations ,
UK ,
Ukraine ,
Vladimir Putin ,
White Collar Crimes
On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more
2/26/2024
/ Anti-Money Laundering ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Proposed Rules ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule setting forth the circumstances under which beneficial ownership information reported to FinCEN pursuant to the Corporate...more
2/9/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Ownership Interest ,
Regulatory Requirements ,
Reporting Requirements
On March 2, the Department of Commerce, Department of Justice, and Department of the Treasury issued a Tri-Seal Compliance Note warning companies to be vigilant for Russia-related sanctions evasion. The Note sets forth a...more
3/14/2023
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Services Industry ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
U.S. regulators are signaling heightened expectations for anti-money laundering compliance within the crypto industry. Although FinCEN issued guidance in 2013 interpreting virtual currency “administrators” and “exchanges” as...more
1/20/2023
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Cryptocurrency ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Money Services Business ,
Popular ,
Proposed Legislation ,
Regulatory Agenda
Two recent OFAC enforcement actions highlight real-world challenges that financial institutions and other companies may face in their efforts to implement an effective sanctions compliance program....more
On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more