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Another Chapter in the Alpine Securities Saga: District Court Grants Motion to Dismiss Complaint Challenging AML Enforcement...

In the possible final stage of the Alpine Securities saga, Judge Clark Waddopous of the United States District Court for the District of Utah issued an opinion granting the Securities and Exchange Commission’s (“SEC”) motion...more

Corporate Transparency Act Litigation Update:  Eleventh Circuit Hears Argument, and District of Oregon Rejects Preliminary...

Various industry groups have filed lawsuits in multiple federal districts challenging the constitutionality of the Corporate Transparency Act (“CTA”). The first such suit, filed in the Northern District of Alabama, resulted...more

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

BSA Filings and Their Utility to Law Enforcement:  An Industry Viewpoint

In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more

BSA Filings and Their Utility to Law Enforcement:  A Guest Blog

Yesterday we were very pleased to welcome guest blogger, Don Fort, who is the Director of Investigations at Kostelanetz LLP, and the past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division....more

FinCEN Releases Year-in-Review for FY 2023: SARs, CTRs and Information Sharing

The Financial Crimes Enforcement Network (“FinCEN”) has issued its Year in Review for FY 2023 (“YIR”). It consists of five pages of infographics. According to FinCEN’s press release...more

IRS Unveils Broad Draft Information Reporting Form for Digital Asset Transactions

On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...more

FinCEN Issues Alert on COVID-19 Employee Retention Tax Credit Fraud

On November 22, 2023, the Financial Crimes Enforcement Network (“FinCEN”), in close coordination with the Internal Revenue Service (“IRS”) Criminal Investigation (“CI”), issued an alert (“Alert”) regarding the COVID-19...more

SDNY Court Finds Broad Fed Powers Over Master Accounts in Puerto Rican Bank Case Involving AML Concerns

The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of New York, denying a...more

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more

Russian Oligarchs and Suspicious Financial Flows: A FinCEN Analysis

The Financial Crimes Enforcement Network (“FinCEN”) issued on December 22 a Financial Trend Analysis regarding Bank Secrecy Act (“BSA”) filings during the period of March to October 2022 (the “Report”) reflecting financial...more

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

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