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Art Market Integrity Act Introduced With Bipartisan Support to Combat Money Laundering Risks in the Art Industry

Senate Judiciary Committee Chairman Chuck Grassley (R-IA) and Senator John Fetterman (D-PA) have introduced the Art Market Integrity Act (AMIA) in Congress....more

Long-Awaited DOJ Guidance on White Collar Enforcement Priorities and Policies: Key Takeaways

This guidance follows a number of Executive Orders (EOs) and other memoranda from the DOJ, including (1) the February 10, 2025 EO pausing enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days, pending the...more

Key Considerations for Compliance Officers Under President Trump

The Trump Administration has ushered in massive shifts in enforcement and policy priorities. From crypto to anti-corruption measures and tariffs to technology, the new Administration has changed the compliance landscape...more

Cartels, China, and Fentanyl-Related Illicit Finance

FinCEN report reveals threat patterns and trends for financial institutions to monitor - The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury (Treasury) published a Financial Trend Analysis...more

How FCPA and FCA Enforcement Could Change Under President Trump

To date, President Donald Trump has signed close to 100 Executive Orders (EOs) that signal the Trump Administration’s policies and key priorities, including objectives related to corporate crime and international trade and...more

CTA Update: FinCEN Revises Beneficial Ownership Information Reporting Requirements and Extends Deadlines

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) significantly revising the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency...more

FinCEN’s Geographic Targeting Order Increases Reporting Obligations for Money Services Businesses Located Near the United...

On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more

CTA Update: Reporting Rule Reinstated; FinCEN Imposes March 21 Reporting Deadline for Most Reporting Companies

On February 17, 2025, the US District Court for the Eastern District of Texas stayed its previous order suspending enforcement of the Corporate Transparency Act (CTA)’s Reporting Rule in Smith v. US Dept. of the Treasury,...more

President Trump’s Executive Order Pauses FCPA Enforcement Pending Attorney General Review

On February 10, 2025, President Donald Trump signed an Executive Order (EO) directing Attorney General (AG) Pam Bondi to pause enforcement of the Foreign Corrupt Practices Act (FCPA) until new enforcement guidelines and...more

AG Bondi Releases Memos on Cartels and Joint Task Force October 7: Implications for Industry

The US Department of Justice (DOJ)’s Attorney General, Pam Bondi, recently released over a dozen memoranda on a variety of policies – ranging from plea agreements and sentencing criteria, to the DOJ’s amplified focus on...more

CTA Update: Supreme Court Grants Stay of Preliminary Injunction on Corporate Transparency Act

On January 23, 2025, the Supreme Court of the United States granted the federal government a stay of the preliminary injunction foreclosing enforcement of the Corporate Transparency Act (CTA) in McHenry v. Texas Top Cop Shop,...more

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Fifth Circuit Vacates Stay of Corporate Transparency Act Injunction, Again Putting Deadlines on Hold

On December 26, 2024, the US Court of Appeals for the Fifth Circuit vacated the stay entered by a motions panel days earlier, which would have allowed the government to enforce the Corporate Transparency Act (CTA) while it...more

Fifth Circuit Stays Injunction Halting Corporate Transparency Act’s Enforcement; Treasury Updates Deadline to January 13, 2025 for...

On December 23, 2024, the US Court of Appeals for the Fifth Circuit issued an order granting the government's emergency motion for a stay pending appeal of the preliminary injunction against the Corporate Transparency Act...more

CFTC Issues Advisory on Use of AI in Regulated Markets

The US Commodity Futures Trading Commission (CFTC) issued a nonbinding staff advisory, CFT Letter No. 24-17, to all CFTC-registered entities and registrants concerning the use of artificial intelligence (AI) in CFTC-regulated...more

Reporting Companies Should Remain Flexible Given Uncertain Future of the Corporate Transparency Act after Texas Court Grants...

Congress passed the Corporate Transparency Act (CTA) as an anti-money laundering initiative in 2021 designed to combat the use of anonymous “shell companies” to facilitate money laundering, terrorist financing, and threaten...more

SEC Enforcement Actions Highlight Anti-Money Laundering Reporting Focus for Financial Gatekeepers

The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more

‘Tis the season and past time for a ho-ho-hum approach to Corporate Transparency Act reporting deadline

Time is running out for Corporate Transparency Act (CTA) compliance. The law, which became effective on January 1, 2024, requires certain entities – or “reporting companies” – to disclose information about their beneficial...more

Minimizing AI Risk: Top Points for Compliance Officers

More than ever, artificial intelligence (AI) is being implemented as a powerful tool to improve our lives and businesses. But with its benefits comes a host of risks – and regulators are homing in on its use as a tool for...more

DOJ's Revised ECCP Signals Expectations of a Data-driven Compliance Program

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced much-anticipated revisions to the US Department of Justice (DOJ)’s Evaluation of Corporate Compliance Programs (Revised ECCP)...more

European Union Deforestation Regulation: What US Companies Should Know

Due diligence requirements under the Regulation on Deforestation-Free Products (EUDR) will apply starting on December 30, 2024, setting in motion a landmark regulation to prevent products linked to deforestation and forest...more

Treasury’s FinCEN and SEC Propose Rule Requiring Investment Advisers to Develop Customer Identification Programs

On May 13, 2024, the Securities and Exchange Commission (SEC) and the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly proposed a new rule that would impose requirements on SEC-registered...more

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