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Corporate Counsel Anti-Money Laundering

Bracewell LLP

FinCEN's Cartel Crackdown on Three Mexican Financial Institutions: Implications for US Financial Transactions

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It just got much riskier to do business in Mexico. On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a novel set of orders finding three financial institutions in...more

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for May 2025

On May 14, 2025, Deputy Enforcement Director Antonia Apps told those gathered at an anti‑money laundering conference in Washington, D.C. to expect a more measured approach from SEC Enforcement. That may include, she...more

ArentFox Schiff

In-House Counsel Should Advise Their Companies to Assess the Political Risks of Their Business Decisions

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Right now, much about the world is uncertain. Risks posed by political changes dominate the headlines and also weigh heavily on many decisions made by businesses, their advisors, and their stakeholders....more

DLA Piper

A Look at Canada’s Ongoing Efforts to Combat Bribery and Corruption

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In October 2023, the Working Group on Bribery in International Business Transactions for the Organization for Economic Co-operation and Development (OECD) released and adopted a report evaluating Canada’s enforcement of the...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

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On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

Ropes & Gray LLP

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

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On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

Paul Hastings LLP

New Industry-Friendly Crypto Regulations May Be on the Way

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Congress and federal agencies have continued to back more industry-friendly crypto regulations and appear to be looking for paths forward for new legislation. Under new leadership, the agencies have indicated a willingness to...more

Pierce Atwood LLP

It Lives: Trump Administration Defends Corporate Transparency Act; May Modify its Application

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On February 5, 2025, the Trump administration added a new chapter to the saga that has been implementation of the Corporate Transparency Act (CTA), filing a notice of appeal and motion for stay against an Eastern District of...more

Morgan Lewis

UK Economic Crime and Corporate Transparency Act: Additional Changes to Roll Out in 2025

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Following the implementation of the Economic Crime and Corporate Transparency Act 2023, Companies House enacted some initial changes over the course of 2024 to improve transparency and ensure the accuracy of the information...more

Pillsbury Winthrop Shaw Pittman LLP

Beneficial Ownership Reporting: Litigation, Pending Legislation and Possible Future Executive Action Have Left the Fate of the...

The saga of the CTA continues. Adopted in January 2021, the Corporate Transparency Act (CTA) is intended to assist in identifying beneficial ownership and control of entities operating in the United States in order to...more

Amundsen Davis LLC

U.S. Supreme Court Provisionally Reinstates the Corporate Transparency Act

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The U.S. Supreme Court issued an order on January 23, 2025, which provisionally reinstates the Corporate Transparency Act (CTA) while a legal challenge to it continues. This brief order, which stayed an injunction against the...more

Blake, Cassels & Graydon LLP

Recyclage des produits de la criminalité et financement des activités terroristes : nouvelle série de modifications

Le 30 novembre 2024, des modifications proposées à des règlements pris en vertu de la Loi sur le recyclage des produits de la criminalité et le financement des activités terroristes (la « LRPCFAT ») ont été publiées. Les...more

Proskauer Rose LLP

Top 10 Whistleblowing and Retaliation Events of 2024

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Following our annual tradition — which started over a decade ago — we are analyzing the year's 10 most significant whistleblower and retaliation events. As you'll see, in 2024, actions taken by a range of courts and...more

Davis Wright Tremaine LLP

CFTC Releases Its Enforcement Results for FY 2024 Showing an All-Time High for Monetary Relief

On December 4, 2024, the CFTC's Division of Enforcement ("Division") released its enforcement results for Fiscal Year 2024. The results reflected an all-time high for monetary relief, mainly from its resolution of off-channel...more

Blake, Cassels & Graydon LLP

But Wait, There’s More: Significant Amendments to Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime

On November 30, 2024, draft amendments to the regulations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the PCMLTFA) were released. These proposed amendments to the regulations would be...more

Allen Matkins

Using A Service To File A Beneficial Ownership Information Report? Be Sure To Read The Small Print

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It cannot be gainsaid that the Corporate Transparency Act has been a major headache for millions of business entities.  The CTA is part of the William M. (Mac) Thornberry National Defense Authorization Act (NDAA) for Fiscal...more

Seyfarth Shaw LLP

FinCEN’s October 2024 Beneficial Ownership Information FAQ Update

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On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

Davis Wright Tremaine LLP

What To Know About FinCEN's Investment Adviser AML Program Final Rule

After two decades and three proposed rulemakings on whether investment advisers should have anti-money laundering (AML) and countering the financing of terrorism (CFT) program requirements and attempting to identify the...more

BCLP

CTA and Corporate Governance: A Quick Guide for Situations Where CTA Comes into Play

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The Corporate Transparency Act (“CTA”) was enacted by The U.S. Congress in January 2021 as a way to protect the United States financial system from being used for money laundering and other illicit activities....more

WilmerHale

Corporate Transparency Act: First Wave of Required Reports Due Starting on March 31, 2024

WilmerHale on

As we have previously reported, the Corporate Transparency Act (“CTA”) is a broad anti-money laundering law intended to assist law enforcement in combating illicit financial activity. The CTA’s beneficial ownership reporting...more

Ballard Spahr LLP

Federal District Court Ruling: The CTA is Unconstitutional

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On March 1, Judge Liles C. Burke of the Northern District of Alabama issued a Memorandum Opinion (“Opinion”) and Final Judgment, finding that the Corporate Transparency Act (“CTA”) is unconstitutional....more

Polsinelli

FinCEN Publishes Updated FAQs to Assist in Reporting Compliance

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The Financial Crimes Enforcement Network (“FinCEN”) recently published updates to its list of Frequently Asked Questions (“FAQs”) to assist entities in complying with the beneficial ownership reporting requirements of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

China Increases Merger Filing Thresholds

China has finally published the long-awaited amendments to its merger control filing thresholds, which will materially impact companies considering mergers, acquisitions and joint ventures this year. The amended Rules on the...more

Kelley Drye & Warren LLP

Instructions for Filing Beneficial Ownership Information Reports under the Corporate Transparency Act

On January 1, 2024, the new beneficial ownership information reporting requirements (BOIR) went into effect under the Corporate Transparency Act (CTA). Among other things, beneficial ownership reporting is intended to make it...more

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