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FinCEN Designates Three Mexican Financial Institutions as Primary Money Laundering Concerns Linked to Opioid Trafficking

On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued three orders designating CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. (collectively,...more

Focused FCPA Enforcement: Emphasizing Security and Strategic Interests

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more

Navigating FinCEN’s Actions on Huione Group: Strengthening Defenses Against Money Laundering

On May 1, 2025, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) regarding the Huione Group, a foreign financial institution located in Cambodia. This proposal, enacted under...more

A New Era for Digital Assets: The Impact of DOJ’s Shift Away from Regulation by Prosecution and Its Implications

In a significant policy shift, Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation By Prosecution,” on April 7, 2025, signaling a change in the Department of Justice’s (DOJ) approach to digital...more

Patriot Bank Enters Agreement with OCC to Address Regulatory Concerns

On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more

Brink’s Global Services Faces Major Fines: The DOJ and FinCEN Crackdown on AML Violations

Brinks Global Services USA (“BGS USA”), a global leader in secure logistics, found itself at the center of a significant regulatory investigation due to its failure to meet anti-money laundering (“AML”) obligations....more

Antitrust Enforcement in the Procurement Space During the Second Trump Administration

Although the scope of federal antitrust enforcement under the second Trump administration remains uncertain, the Procurement Collusion Strike Force (PCSF) is expected to remain active. The PCSF, which was started by the first...more

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

Blockchain Analysis and Related Expert Testimony Admissible In Criminal Trial

It is challenging for law enforcement to track down and trace illicit activities conducted through digital currencies. The process can be very time- and resource-intensive. Further, securing charges and arrests, and...more

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