On June 25, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying three Mexican financial institutions as being of primary money laundering concern in connection with...more
In a May 12, 2025, memorandum (the May Memorandum) on focus, fairness and efficiency in the fight against white collar crime, the Department of Justice (DOJ) Criminal Division1 again identified the total elimination of...more
On December 26, 2024, the Fifth Circuit merits panel assigned to Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, reinstated a nationwide preliminary injunction enjoining enforcement of the Corporation Transparency Act and...more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
This alert has been updated to reflect FinCEN’s extension of the deadline after the alert was first sent.
On December 23, 2024, after expedited briefing, a three-judge panel of the Fifth Circuit in Texas Top Shop v....more
12/24/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Time Extensions
The Corporate Transparency Act (CTA) and its implementing regulations (Regulations) require entities within its scope (reporting companies) to disclose information, including about their beneficial owners, to the U.S....more
12/16/2024
/ Business Ownership ,
Corporate Counsel ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Suspended Judgment ,
Unconstitutional Condition
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule (the Proposed Rule) to implement certain aspects of the Anti-Money Laundering Act of 2020 (the AML Act), which updated the...more
7/17/2024
/ AML/CFT ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Bank Secrecy Act ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Investment Management ,
Popular ,
Proposed Rules ,
Securities and Exchange Commission (SEC)
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more
5/30/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
CFIUS ,
Customer Identification Program (CIP) ,
Financial Institutions ,
FinCEN ,
Policies and Procedures ,
Proposed Rules ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
The Corporate Transparency Act and its implementing regulations (together CTA) came into effect on January 1, 2024, requiring entities within its scope to disclose information, including about their beneficial owners, to the...more
2/2/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Governance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
New York ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
The Proposed Rule Aims To Increase Transparency in CVC Mixing -
On October 19, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a notice of proposed rulemaking (Proposal)...more
Through a series of coordinated actions in May 2023, the United States launched a whole-of-government effort to expand and strengthen enforcement of its sanctions campaign against Russia as the conflict in Ukraine continues...more
6/6/2023
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
FinCEN ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia
On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more
2/7/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Crypto Exchanges ,
Cryptocurrency ,
Enforcement Actions ,
EU ,
Financial Crimes ,
FinCEN ,
Law Enforcement ,
Money Laundering ,
NDAA ,
Patriot Act ,
Popular ,
Russia ,
U.S. Treasury ,
Virtual Currency ,
White Collar Crimes
On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more
On September 29, 2022, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a long-awaited final rule implementing the beneficial ownership information (BOI) reporting requirements of the...more
Even though significant sanctions and export controls have already been put in place, the United States recently adopted additional measures targeting key elements of the Russian economy and military industry in response to...more
On December 7, 2021, the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting...more
The President’s Working Group on Financial Markets (PWG), together with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a much-anticipated Report on...more
11/17/2021
/ AML/CFT ,
Bank Holding Company Act ,
Banking Regulators ,
Biden Administration ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
FDIC ,
Financial Institutions ,
FinCEN ,
FinTech ,
OCC ,
Stablecoins ,
Virtual Currency ,
Working Groups
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more
On October 18, 2021, the U.S. Department of the Treasury released the results of its broad review of economic and financial sanctions. The review, initiated by the Biden administration, included discussions with Congress,...more
On October 8, 2021, the Financial Industry Regulatory Authority (FINRA) issued a Regulatory Notice urging its member firms (i.e., broker-dealers) to consider how they will incorporate the U.S. Treasury Department’s...more
In recent months, the increased focus on cryptocurrency regulation and enforcement at both the federal and state levels demonstrates the digital currency’s place as an established component of the financial landscape. At the...more
10/1/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
FinCEN ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
IRS ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
This issue discusses a variety of legal, regulatory and enforcement developments in the digital asset space in the U.S. and Europe, including expanded reporting requirements for broadly defined cryptocurrency “brokers,” a...more
8/27/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Enforcement Actions ,
FinCEN ,
Popular ,
Reporting Requirements ,
Smart Contracts
On June 30, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first government-wide priorities (Priorities) for combatting money laundering and the financing of terrorism.1...more
7/22/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Financial Institutions ,
FinCEN ,
Human Trafficking ,
Internal Controls ,
National Security ,
Terrorist Financing ,
Terrorist Financing Regulations
The first 100 days of the Biden administration has coincided with a watershed period in the evolution of blockchain technology and cryptocurrencies. The price of Bitcoin has risen dramatically during that period, triggering...more
Sanctions -
The Biden administration has made clear that economic sanctions will continue to be an important U.S. foreign policy tool and has initiated a comprehensive review of current sanctions policies and practices....more
On April 1, 2021, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comments on the implementation of the Corporate...more