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New Lessons in Regulation, August 2025 - FinCEN Extends Effectiveness Date of Orders Targeting CIBanco, Intercam, and Vector until...

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

Operation and Structure of the GENIUS Act of 2025 on Payment Stablecoins

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

Rules in Motion, May 2025 - U.S. Issues Broad Sanctions Relief for Syria

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

U.S. Treasury Department Suspends Enforcement of Corporate Transparency Act Against Domestic Reporting Companies and U.S....

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

Court Finds Corporate Transparency Act Unconstitutional and Unenforceable as to NSBA Members

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

Tri-Seal Compliance Note Warns of Sanctions Evasion

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

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