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DOJ and SEC Send Warning on “AI Washing” with Charges Against Technology Startup Founder

The US Department of Justice (DOJ) announced a criminal indictment and the Securities and Exchange Commission (SEC) announced a civil complaint against the founder and former CEO of an e-commerce technology startup. DOJ and...more

Cartels, China, and Fentanyl-Related Illicit Finance

FinCEN report reveals threat patterns and trends for financial institutions to monitor - The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury (Treasury) published a Financial Trend Analysis...more

SEC Roundtable Presents Both Risks and Opportunities of AI in the Financial Industry

The Securities and Exchange Commission (SEC) recently hosted a Roundtable on Artificial Intelligence in the Financial Industry in Washington, DC (SEC AI Roundtable). The day-long event, which took place on March 27, 2025,...more

FinCEN’s Geographic Targeting Order Increases Reporting Obligations for Money Services Businesses Located Near the United...

On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more

CTA Update: Reporting Rule Reinstated; FinCEN Imposes March 21 Reporting Deadline for Most Reporting Companies

On February 17, 2025, the US District Court for the Eastern District of Texas stayed its previous order suspending enforcement of the Corporate Transparency Act (CTA)’s Reporting Rule in Smith v. US Dept. of the Treasury,...more

AG Bondi Releases Memos on Cartels and Joint Task Force October 7: Implications for Industry

The US Department of Justice (DOJ)’s Attorney General, Pam Bondi, recently released over a dozen memoranda on a variety of policies – ranging from plea agreements and sentencing criteria, to the DOJ’s amplified focus on...more

Recent Settlement Demonstrates DOJ’s Focus on Foreign Entities Misrepresenting Anti-Money Laundering Compliance

The US Department of Justice (DOJ) has announced that Wall Street Exchange (WSE), a Dubai-based money exchange service provider, entered into a non-prosecution agreement (NPA) and agreed to pay more than $9.2 million to...more

Blockchain and Digital Assets News and Trends – January 2025

This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more

CTA Update: Supreme Court Grants Stay of Preliminary Injunction on Corporate Transparency Act

On January 23, 2025, the Supreme Court of the United States granted the federal government a stay of the preliminary injunction foreclosing enforcement of the Corporate Transparency Act (CTA) in McHenry v. Texas Top Cop Shop,...more

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Fifth Circuit Vacates Stay of Corporate Transparency Act Injunction, Again Putting Deadlines on Hold

On December 26, 2024, the US Court of Appeals for the Fifth Circuit vacated the stay entered by a motions panel days earlier, which would have allowed the government to enforce the Corporate Transparency Act (CTA) while it...more

Fifth Circuit Stays Injunction Halting Corporate Transparency Act’s Enforcement; Treasury Updates Deadline to January 13, 2025 for...

On December 23, 2024, the US Court of Appeals for the Fifth Circuit issued an order granting the government's emergency motion for a stay pending appeal of the preliminary injunction against the Corporate Transparency Act...more

Reporting Companies Should Remain Flexible Given Uncertain Future of the Corporate Transparency Act after Texas Court Grants...

Congress passed the Corporate Transparency Act (CTA) as an anti-money laundering initiative in 2021 designed to combat the use of anonymous “shell companies” to facilitate money laundering, terrorist financing, and threaten...more

SEC Enforcement Actions Highlight Anti-Money Laundering Reporting Focus for Financial Gatekeepers

The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more

‘Tis the season and past time for a ho-ho-hum approach to Corporate Transparency Act reporting deadline

Time is running out for Corporate Transparency Act (CTA) compliance. The law, which became effective on January 1, 2024, requires certain entities – or “reporting companies” – to disclose information about their beneficial...more

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