On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more
7/23/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Biden Administration ,
BSA/AML ,
Compliance ,
Customer Identification Program (CIP) ,
Final Rules ,
Financial Regulatory Reform ,
FinCEN ,
Investment Adviser ,
Registered Investment Advisors ,
Regulatory Reform ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more
6/30/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Broker-Dealer ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Mexico ,
New Legislation ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more
6/24/2025
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Cayman Islands ,
Compliance Dates ,
Customer Identification Program (CIP) ,
Filing Requirements ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Investment Management ,
Patriot Act ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Regulatory Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more
6/18/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Civil Monetary Penalty ,
Due Diligence ,
Economic Sanctions ,
Financial Crimes ,
Fund Managers ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Private Equity ,
Russia ,
Sanction Violations ,
SDN List ,
U.S. Treasury ,
Ukraine ,
Venture Capital
On June 9, Deputy Attorney General Todd Blanche issued a memorandum (the Memorandum) outlining revised guidelines for investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The U.S. Department of Justice...more
6/12/2025
/ Anti-Corruption ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
New Guidance ,
Regulatory Reform ,
Risk Management ,
Trump Administration
Last Friday, the U.S. Department of Justice (DOJ) unsealed its first indictment against a foreign national for providing material support to a Mexican drug cartel that the current administration recently designated a foreign...more
5/22/2025
/ Bank Secrecy Act ,
Cartels ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Financial Crimes ,
FinCEN ,
Indictments ,
Mexico ,
Money Laundering ,
National Security ,
SAR ,
Terrorism Funding ,
Trump Administration
Last week, U.S. Department of Justice (DOJ) Head of the Criminal Division Matthew R. Galeotti announced key changes to the DOJ’s enforcement priorities during his keynote address at the Securities Industry and Financial...more
As discussed in our March 4 Client Alert, following its February 27 and March 2 announcements suspending enforcement of the Corporate Transparency Act (CTA) and promising additional CTA compliance guidance, on the evening of...more
As discussed in our prior client alert, following the February 18 decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Dep’t of Treasury to stay a nationwide injunction it previously entered...more
Regular readers of our prior client alerts know that compliance with the Corporate Transparency Act’s (CTA) beneficial ownership requirements has been on-again-off-again multiple times over the last few months following...more
In a surprise ruling, December 26, the Fifth Circuit Court of Appeals vacated its own stay of the Eastern District of Texas’ Dec. 3 nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act...more
The U.S. Court of Appeals for the Fifth Circuit has granted the government’s motion to stay the Eastern District of Texas’ December 3 nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act...more
12/26/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Appeals ,
Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
On December 3, 2024, a federal district court in Texas issued a nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA).1 The court indicated that the CTA is “likely unconstitutional,”...more
On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more
10/15/2024
/ Bank Secrecy Act ,
Banks ,
BSA/AML ,
Department of Justice (DOJ) ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
OCC ,
Popular ,
Professional Disciplinary Actions ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
On September 20, the District Court for the District of Oregon denied a motion for a preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA) on the basis that the plaintiffs’ claim that the CTA...more
In response to illicit finance risks identified in the U.S. residential real estate sector, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced the issuance of its long-anticipated...more
9/3/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficiaries ,
BSA/AML ,
Final Rules ,
FinCEN ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Trusts ,
U.S. Treasury
On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more
9/3/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Customer Identification Program (CIP) ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Patriot Act ,
Popular ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
On May 23, 2024, the California Senate passed a bill that, if approved by the California Assembly before August 31, 2024, and signed into law by Gov. Gavin Newsom, would require U.S. and foreign entities doing business in...more
On May 13, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a joint notice of a proposed rulemaking (NPRM) that would require...more
On Friday, March 1, 2024, U.S. District Court Judge Liles Burke ruled that the Corporate Transparency Act (CTA) is unconstitutional because Congress exceeded its powers to regulate interstate commerce, oversee foreign affairs...more
On Feb. 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM)1 in response to illicit finance risks identified in the U.S. residential real estate...more
The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a notice of proposed rulemaking (NPRM) that would subject registered investment advisers (RIAs) and exempt reporting...more
2/16/2024
/ AML/CFT ,
Bank Secrecy Act ,
Customer Due Diligence (CDD) ,
FinCEN ,
Investment Adviser ,
NPRM ,
Patriot Act ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
U.S. Treasury
The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more
On Dec. 22, New York Governor Kathy Hochul signed the New York Limited Liability Company Transparency Act (“NY LLC Transparency Act”) into law. The NY LLC Transparency Act is modeled on the Corporate Transparency Act (“CTA”),...more
On November 29, 2023, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (RIN 1506-AB62)1, extending the deadline for companies created or registered in 2024 to file beneficial owner...more