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UPDATE: Effective date regarding FinCEN’s new Section 2313a Orders against three Mexican financial institutions

U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions have until 21 July to implement compliance procedures. Transfers of funds involving these designated Mexican...more

FinCEN invokes new Section 2313a authority against three Mexican financial institutions: The who, what, when, where, why, and...

The orders represent the first use of new authorities by FinCEN. U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions will be subject to significant compliance obligations,...more

Treasury announces there will be no penalties or fines for failure to file CTA beneficial ownership reports and proposes to narrow...

Key takeaways FinCEN and Treasury announce that there will be no enforcement for failure to file beneficial ownership information reports with FinCEN by the March 21 deadline. Treasury announced intention to narrow the scope...more

CTA reporting requirements reinstated with March 21, 2025 deadline for most non-exempt reporting companies

As described in our previous client alert, on January 23, 2025, the Supreme Court of the United States stayed the nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas...more

CTA Required Reporting Still on Hold: Recent Supreme Court ruling affects one CTA beneficial ownership case, but other case...

Key takeaways TLDR: No mandatory BOI/CTA filing yet, but stay tuned pending resolution of a second case and subsequent FinCEN guidance. On January 23, 2025, the Supreme Court of the United States stayed the nationwide...more

FinCEN provides regulatory relief to casinos, allowing “non-documentary” identification verification

On October 19, 2021, FinCEN, the U.S. Government’s lead AML regulator, exercised its regulatory relief authority to allow casinos and card clubs to employ “non-documentary means” to verify patrons’ identity. The original...more

Treasury Department issues ransomware guidance in response to significant uptick in ransomware attacks

In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more

U.S. government announces enhanced due diligence process for humanitarian trade with Iran and identifies Iran as a jurisdiction of...

On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran. Foreign governments and foreign financial institutions...more

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