On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more
On January 2, 2025, the U.S. Department of the Treasury’s (Treasury) regulation restricting U.S. outbound investments in certain advanced technology sectors in China (the Final Rule) takes effect. Thereafter, investments by...more
12/31/2024
/ Artificial Intelligence ,
CFIUS ,
Covered Transactions ,
Final Rules ,
Foreign Investment ,
Foreign Persons ,
Lawful Permanent Residents ,
National Security ,
Outbound Transactions ,
Private Equity ,
Prohibited Transactions ,
Technology ,
U.S. Treasury
The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more
President Biden issued a long-awaited executive order, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the Executive Order or E.O.), on August 9, 2023,...more
8/17/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Compliance ,
Corporate Governance ,
Covered Person ,
Exceptions ,
Executive Orders ,
Foreign Direct Investment ,
Investment ,
Investors ,
National Security ,
Popular ,
Technology Sector ,
U.S. Treasury ,
White Collar Crimes
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
Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more
3/22/2022
/ Anti-Money Laundering ,
Anti-Terrorism Financing ,
Bank Secrecy Act ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
FinCEN ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Russia ,
SDN List ,
SWIFT ,
U.S. Treasury ,
UK ,
Ukraine
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more
10/20/2021
/ Compliance ,
Corporate Counsel ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Financial Services Industry ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Regulatory Oversight ,
Risk Assessment ,
SDN List ,
Strict Liability ,
U.S. Treasury ,
Virtual Currency
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
10/5/2021
/ Crypto Exchanges ,
Currency Exchange ,
Cyber Attacks ,
Cybersecurity ,
Economic Sanctions ,
Enforcement Actions ,
Guidance Update ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
U.S. Treasury ,
Virtual Currency
On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more
9/22/2021
/ Anti-Money Laundering ,
Anti-Retaliation Provisions ,
Bank Secrecy Act ,
BSA/AML ,
Corporate Transparency Act ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Employees ,
Financial Institutions ,
Money Laundering ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury ,
Whistleblower Awards ,
Whistleblowers
As we reported in April, the Anti-Money Laundering Act of 2020 (AMLA 2020) aims to strengthen protections against money laundering, terrorism financing, and other illegal activities through a variety of mechanisms, including...more
7/15/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Disclosure Requirements ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
New Rules ,
Reporting Requirements ,
Terrorist Financing Regulations ,
U.S. Treasury