News & Analysis as of

Department of Justice (DOJ) Enforcement Actions 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

Herbert Smith Freehills Kramer

US Corporate Governance — 2025 Midyear Review

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....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

Lowenstein Sandler LLP

First Terrorism Indictments Announced Over Drug Cartel Support

Lowenstein Sandler LLP on

Last Friday, the U.S. Department of Justice (DOJ) unsealed its first indictment against a foreign national for providing material support to a Mexican drug cartel that the current administration recently designated a foreign...more

DLA Piper

US Treasury Takes on Cartels Part Deux: Combating Cartel-Connected Oil Smuggling Schemes

DLA Piper on

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in coordination with the Office of Foreign Assets Control (OFAC), the US Drug Enforcement Administration (DEA), the Federal Bureau of...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

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

Orrick, Herrington & Sutcliffe LLP

Treasury suspends enforcement of beneficial ownership information reporting for U.S. companies, focuses on foreign entities

On March 2, the Treasury announced it will suspend enforcement of fines or penalties indefinitely for beneficial ownership information (BOI) reporting. This suspension of enforcement will be for U.S. domestic reporting...more

Greenbaum, Rowe, Smith & Davis LLP

Another Urgent Update: Corporate Transparency Act is Again Enforceable with New Deadline for Reporting

We previously reported that on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the Fifth Circuit motion panel’s stay of the Corporate Transparency Act (CTA) of the temporary injunction granted by...more

Bracewell LLP

Corporate Transparency Act Reporting Obligations Effective Again With March 21, 2025, Deadline for Most Reporting Companies

Bracewell LLP on

On February 17, 2025, the US District Court for the Eastern District of Texas (EDTX) in Smith, et. al. v. US Department of the Treasury, et. al., entered an order staying the nationwide injunction on enforcement of the...more

Brooks Pierce

Corporate Transparency Act: March 21, 2025 Reporting Deadline

Brooks Pierce on

Effective February 18, 2025, and until further notice, beneficial ownership information report filings under the Corporate Transparency Act are once again legally required. The deadline for most reporting companies to file...more

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

Troutman Pepper Locke on

On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...more

Bond Schoeneck & King PLLC

Corporate Transparency Act Filing Requirements Reinstated: U.S. District Court for the Eastern District of Texas Grants Federal...

On Feb. 17, 2025, the U.S. District Court for the Eastern District of Texas (in Smith, et al. v. U.S. Department of the Treasury, et al.) granted the federal government’s motion to stay a nationwide preliminary injunction...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

Fox Rothschild LLP

Corporate Transparency Act Back in Effect

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

Ruder Ware

Yo-Yo-Yo: CTA is Back

Ruder Ware on

The Corporate Transparency Act (CTA) and its reporting requirements are back in effect. This afternoon, a federal district court in Texas granted the U.S. government’s motion to stay (i.e., pause) the nationwide CTA...more

Ballard Spahr LLP

Brink’s Global Services Faces Major Fines: The DOJ and FinCEN Crackdown on AML Violations

Ballard Spahr LLP on

Brinks Global Services USA (“BGS USA”), a global leader in secure logistics, found itself at the center of a significant regulatory investigation due to its failure to meet anti-money laundering (“AML”) obligations....more

Kerr Russell

Corporate Transparency Act Enforcement Expected to Resume Following Legal Developments

Kerr Russell on

While the United States Supreme Court recently lifted one nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Incorporated et al. v. McHenry (formerly Garland),...more

Neal, Gerber & Eisenberg LLP

DOJ Seeks to Reinstate Corporate Transparency Act

On February 5, 2025, the Department of Justice (DOJ) filed a notice of appeal and motion for stay of the injunction against enforcement of the Corporate Transparency Act (CTA) issued by the Eastern District of Texas in Smith...more

A&O Shearman

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

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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

Dickinson Wright

Supreme Court Stays Fifth Circuit CTA Injunction, But Clarity Remains Elusive

Dickinson Wright on

On Jan. 23, 2025, the United States Supreme Court reinstated a stay on the Fifth Circuit Court of Appeals’ Dec. 26, 2024, decision, which had upheld a lower court’s nationwide injunction blocking enforcement of the Corporate...more

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