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The Tornado Cash Trial’s Mixed Verdict: Implications for Developer Liability

On August 6, 2025, following a four-week trial, a jury in the Southern District of New York delivered a mixed verdict in the criminal case against Tornado Cash co-founder Roman Storm. The jury convicted Storm of conspiring to...more

FinCEN's First Strike: New Section 311 Powers Target Mexican Financial Institutions Under FEND Off Fentanyl Act

In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more

FinCEN Designates Three Mexican Financial Institutions Under New Section 311 Authority: First Use of Expanded Powers Under FEND...

On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

FinCEN Confirms Suspension of Corporate Transparency Act

FinCEN has confirmed that, since December 7, 2024, reporting companies have not been, and will continue to not be, required to file beneficial ownership reports for as long as an injunction of the CTA remains in effect....more

FinCEN Proposes Rule Reinforcing Financial Institutions’ Duty to Design and Maintain Risk-Based AML/CFT Programs

On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more

FinCEN Proposes New Residential Real Estate Reporting Requirements

On February 7, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking on certain US residential real estate transactions (“2024 NPRM”). The 2024 NPRM...more

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