The Fifth Circuit has granted the government’s request to stay temporarily the order and injunction issued by the United States District Court for the Eastern District of Texas, which had issued a nationwide stay prohibiting...more
12/24/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
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
8/5/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
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
7/29/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations
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
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
6/11/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Currency Transaction Reports (CTR) ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Information Sharing ,
Money Laundering ,
Suspicious Activity Reports (SARs)
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
11/17/2023
/ Administrative Procedure Act ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Declaratory Judgments ,
Department of Justice (DOJ) ,
Due Process ,
Enforcement Actions ,
Federal Reserve ,
Financial Crimes ,
Financial Institutions ,
Money Laundering ,
Preliminary Injunctions ,
Puerto Rico ,
Suspicious Activity Reports (SARs)
The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”). They pertain, in part, to a proposed extension of the filing deadline for certain...more
10/2/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Comment Period ,
Corporate Transparency Act ,
Filing Deadlines ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
National Security ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice entitled “FinCEN Calls Attention to Payroll Tax Evasion and Workers’ Compensation Fraud in the Construction Sector” (the “Notice”). According to the...more
8/17/2023
/ Anti-Money Laundering ,
Construction Industry ,
Currency Transaction Reports (CTR) ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
FinCEN ,
Payroll Taxes ,
Popular ,
Tax Evasion ,
Wage and Hour ,
Workers' Compensation Claim
As we have blogged repeatedly, there is a close nexus between money laundering and tax crimes. The frequent connection between the two sets of offenses – and the potentially related methods of combatting them – is a topic...more
On March 24, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a press release and published initial guidance to assist the public in understanding the beneficial ownership information (BOI) reporting...more