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
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
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
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
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 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
A little over a week has passed since the Federal Deposit Insurance Corp. (FDIC) became receiver of Silicon Valley Bank (SVB) and Signature Bank (Signature), and since the issuance of the joint statement by the FDIC, the U.S....more