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FinCEN Uses “Special Measures” To Combat Fentanyl Money Laundering, Raising Concerns Around Targeted Mexican Financial...

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) took a historic step in combating the fentanyl crisis on June 25, 2025, by exercising, for the first time, the expansive authorities granted...more

DOJ Signals Renewed Prioritization of Corporate Enforcement with New Policies Regarding Voluntary Disclosure, Monitors, &...

On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more

Corporate Transparency Act: Filing Requirements Once Again Voluntary – FinCEN Announces No Enforcement Action for Reporting...

Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more

Trump Halts FCPA Enforcement, for Now, and Appears to Open Pathway to Reexamine Prior FCPA Settlements

The Foreign Corrupt Practices Act (FCPA), passed in the wake of Watergate, prohibits U.S.-linked companies and individuals from bribing foreign government officials to procure international business and hiding the bribes in...more

DOJ Announces Pilot Program and Updated Expectations on Corporate Compensation Programs

The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more

DOJ Issues New Guidance on Use of Personal Devices and Third-Party Messaging Applications

The U.S. Department of Justice (DOJ) announced significant new guidance on March 3, 2023, regarding the use of personal devices and the retention of corporate communications. The DOJ’s concern regarding the use of personal...more

DOJ Announces Shift Toward Corporate Enforcement for Sanctions and Export Control Violations

Deputy Attorney General (DAG) Lisa Monaco once again delivered groundbreaking remarks at the American Bar Association (ABA) National Institute on White Collar Crime (ABA White Collar Conference) on March 2, 2023, this time...more

DOJ Announces Sweeping Policy Updates Targeting Corporate Criminal Enforcement and Individual Accountability

Deputy Attorney General (DAG) Lisa Monaco announced several significant policy updates affecting the U.S. Department of Justice’s (DOJ) enforcement practices for both corporations and individuals on September 15, 2022...more

OFAC Takes Action Against Virtual Currency Tornado Cash in Novel Application of Sanctions Authorities

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of...more

US Treasury Highlights Anti-Money Laundering Priorities in 2022 Illicit Finance Strategy

The U.S. Department of the Treasury (Treasury), on May 13, 2022, published its 2022 National Illicit Finance Strategy (the 2022 Strategy)—a comprehensive statement of the agency’s key priorities, goals, and plans for...more

OFAC Issues Second Ransomware Advisory and Designates Virtual Currency Exchange for Sanctions

Agency’s Focus on Cryptocurrency and Blockchain Continues - On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an updated advisory to “highlight the sanctions...more

The Anti-Money Laundering Act of 2020: A Survey of Key Provisions and Practice Takeaways

On New Year’s Day 2021, Congress overrode a presidential veto to pass the Anti-Money Laundering Act of 2020 (AMLA 2020), which amends and modernizes the Bank Secrecy Act (BSA). The AMLA 2020 includes sweeping reforms updating...more

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