News & Analysis as of

Department of Justice (DOJ) 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

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

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

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

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

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

IR Global

Corporate Transparency Act – Reporting Obligations are Back in Effect

IR Global on

The Financial Crimes’s Enforcement Network of the U.S. Treasury Department (“FinCEN”) Beneficial Ownership Information (“BOI”) reporting obligations under the Corporate Transparency Act (“CTA”) are once again back in effect....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

Saiber LLC

The Saiber Construction Law Column: February 2025

Saiber LLC on

The Corporate Transparency Act was passed in 2021 and took effect January 1, 2024. The purpose of the act is to help combat money laundering, fraud, and terrorism by requiring certain non exempt private companies to report...more

Allen Barron, Inc.

Is it Too Soon for a BOI Report Obituary?

Allen Barron, Inc. on

Is it too soon for a BOI report obituary? After a recent declaration by the U.S. Department of Justice, the FinCEN Beneficial Ownership Interest reporting requirements may be a thing of the past for American companies....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

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

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

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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

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

McCarter & English, LLP

The Evolution of the CTA: Beneficial Ownership Information Reports Are Due by March 21, 2025

As of February 18, 2025, the US Department of the Treasury Financial Crimes Enforcement Network’s (FinCEN) Corporate Transparency Act (CTA) reporting requirements have been restored—at least temporarily. The new filing...more

Vinson & Elkins LLP

Corporate Transparency Act: Once Again Enforceable – New Compliance Dates Apply

Vinson & Elkins LLP on

As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting...more

Snell & Wilmer

The Corporate Transparency Act: Will the New Deadline to Report Survive?

Snell & Wilmer on

On February 17, 2025, the U.S. District Court for the Eastern District of Texas, in Smith, et al. v. U.S. Department of the Treasury, granted the Department of Justice’s request to stay the nationwide injunction that had...more

Miller Canfield

Recent Developments: Nationwide CTA Injunction Lifted, New March 21, 2025, Reporting Deadline Set, and Reporting Rule May Be...

Miller Canfield on

On January 23, 2025, the United States Supreme Court (SCOTUS) reversed the U.S. district court’s preliminary injunction staying the Corporate Transparency Act (CTA) and the implementing Reporting Rule in Texas Top Cop Shop v...more

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