News & Analysis as of

Department of Justice (DOJ) Anti-Money Laundering FinCEN

Morgan Lewis

FinCEN Issues First Transaction Ban on Certain Mexico-Based Financial Institutions

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In a historic first, the US Department of the Treasury’s Financial Crimes Enforcement Network recently published orders prohibiting transactions with covered Mexico-based financial institutions. On June 30, 2025, the US...more

Mayer Brown

FinCEN Designates Three Mexican Financial Institutions Under New Section 311 Authority: First Use of Expanded Powers Under FEND...

Mayer Brown on

On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more

Bradley Arant Boult Cummings LLP

Washington’s War on Cartels Continues: What Financial Institutions Should Know About Oil Smuggling, Money Laundering &...

The Trump administration remains focused on countering Mexican cartels and other Latin American transnational criminal organizations (TCOs). Since designating eight TCOs as foreign terrorist organizations (FTOs), the...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Reinforces Focus on Cartels and Transnational Criminal Organizations

In a May 12, 2025, memorandum (the May Memorandum) on focus, fairness and efficiency in the fight against white collar crime, the Department of Justice (DOJ) Criminal Division1 again identified the total elimination of...more

King & Spalding

Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act

King & Spalding on

The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more

Paul Hastings LLP

Anti-Money Laundering Enforcement Risk Still Remains for Virtual Asset Services Providers

Paul Hastings LLP on

Despite the Trump administration’s generally favorable stance toward cryptocurrency and blockchain innovation, virtual asset services providers (VASPs) must remain vigilant in complying with anti-money laundering (AML)...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels - UPDATED 3/18/25

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

Ballard Spahr LLP

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

Ballard Spahr LLP on

We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

A&O Shearman

Cryptocurrency Exchange Pleads Guilty To Violating Anti-Money Laundering Laws, Agrees To Pay More Than $500 Million In Penalties...

A&O Shearman on

On Monday, February 24, 2025, the U.S. Attorney’s Office for the Southern District of New York (the “SDNY”), in conjunction with the FBI, announced that a Seychelles-based cryptocurrency exchange (“the Exchange”) pled guilty...more

Akin Gump Strauss Hauer & Feld LLP

Establishment of the Strategic Bitcoin Reserve and United States Digital Asset Stockpile

The Secretary of the Treasury shall establish an office to administer and maintain control of custodial accounts collectively known as the “United States Digital Asset Stockpile,” capitalized with all digital assets owned by...more

The Volkov Law Group

Mitigating Risks of “Interacting” with Cartels and TCOs

The Volkov Law Group on

We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs).  Companies need to understand the laws used to...more

Proskauer Rose LLP

Ping Pong Rules: Corporate Transparency Act Back in Effect (Again)

Proskauer Rose LLP on

On February 18, 2025, U.S. District Judge Jeremy Kernodle of the Eastern District of Texas stayed his prior injunction against enforcement of the Corporate Transparency Act (the “CTA”) pending appeal by the U.S. Department of...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect: March 21 Is the New Deadline to File Beneficial Ownership Reports

Fox Rothschild LLP on

The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Orrick, Herrington & Sutcliffe LLP

Cryptoasset exchange pleads guilty for unlicensed money transmitting

On January 27, DOJ announced a cryptocurrency exchange platform (the platform) pled guilty to operating as an unlicensed money transmitting business and failing to implement adequate AML and know-your-customer (KYC) programs....more

A&O Shearman

Major Crypto Exchange Pleads Guilty, Agrees To $297 Million Penalty; Founders Secure DPAs

A&O Shearman on

On January 27, 2025, one of the largest global cryptocurrency exchange platforms (the “Exchange”) pled guilty to one count of operating an unlicensed money transmitting business and agreed to pay $297 million in connection...more

BakerHostetler

Weekly Blockchain Blog - February 2025

BakerHostetler on

US Crypto Companies Expand Via New Licenses, Products, Integrations - A major U.S. cryptocurrency exchange recently announced that it has “secured a Virtual Asset Service Provider (VASP) registration from Argentina’s...more

Vinson & Elkins LLP

Supreme Court Grants Stay of Preliminary Injunction Against Corporate Transparency Act – Second Injunction Still In Effect

Vinson & Elkins LLP on

On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more

Amundsen Davis LLC

Another Twist in the Corporate Transparency Act Saga: FinCEN Announces That Ownership Information Reporting Is Not Currently...

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in an alert posted on its website on January 24, 2025, that reporting companies under the Corporate Transparency Act (CTA) are not...more

Ropes & Gray LLP

Crypto Quarterly Digital Assets, Blockchain and Related Technologies Update

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The landscape of government enforcement, private litigation and federal and state regulation of digital assets, blockchain and related technologies is constantly evolving. Each quarter, Ropes & Gray attorneys analyze...more

Amundsen Davis LLC

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

Amundsen Davis LLC on

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

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Rivkin Radler LLP

The Status of the Corporate Transparency Act – It’s Not Clear

Rivkin Radler LLP on

Few would argue that the federal government does not have a legitimate interest in preventing, detecting, and punishing tax fraud, money laundering, and other financial crimes. Likewise, I imagine few would disagree with the...more

Epstein Becker & Green

Enforcement of Corporate Transparency Act Halted by Federal Court

Epstein Becker & Green on

Following the decision of a federal court on December 3, 2024, enjoining enforcement of the Corporate Transparency Act (the “Act”), FinCEN announced last week that reporting companies are not currently required to file...more

Bradley Arant Boult Cummings LLP

$3B TD Bank AML Settlement Is A Wake-Up Call For All Banks

On Oct. 10, Attorney General Merrick Garland announced that TD Bank pled guilty to conspiracy to commit money laundering and agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice's...more

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