News & Analysis as of

Enforcement Actions Anti-Money Laundering Compliance

Baker Botts L.L.P.

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

Baker Botts L.L.P. on

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

Cadwalader, Wickersham & Taft LLP

FinCEN Uses the FEND Off Fentanyl Act for First Time to Prohibit Funds Transfers with Three Mexican Financial Institutions

On June 25, 2025, FinCEN announced its first orders under the 2024 FEND Off Fentanyl Act, finding that three Mexican financial institutions—CIBanco S.A. Institución De Banca Multiple (“CIBanco"), Intercam Banco S.A.,...more

Lippes Mathias LLP

The Future of Monitorships

Lippes Mathias LLP on

In 2008, then-President Barack Obama famously said, “Elections have consequences.” Seventeen years later that statement is still true. A change in administration at either the federal or state government level ushers in new...more

Thomas Fox - Compliance Evangelist

2 Gurus Talk Compliance: Episode 51 – The Compliance Week at 20 Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more

Thomas Fox - Compliance Evangelist

10 For 10: Top Compliance Stories For the Week Ending April 12, 2025

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to...more

Buchalter

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

Buchalter on

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

Holland & Hart LLP

The CTA Is Back (Sort Of)—What Reporting Companies Need to Know

Holland & Hart LLP on

After months of litigation—including a cameo before the Supreme Court—the last nationwide injunction of the Corporate Transparency Act (CTA) was vacated and the CTA was set to go back into effect. Since then, nothing has been...more

SEC Compliance Consultants, Inc. (SEC³)

Predictions for 2025: What Private Fund Advisers Can Expect from SEC Examinations

There has been a lot of conjecture that the SEC may become friendlier to registrants because of the new administration. Given the SEC’s mandate to protect the investing public, however, we do not expect SEC examiners to...more

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

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Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more

Proskauer - Regulatory & Compliance

Ping-Pong Match Appears Over: US Companies Apparently Definitively Relieved of Compliance Obligations Under the Corporate...

The Corporate Transparency Act (the CTA) requires a range of entities, primarily smaller, unregulated companies, to file reports with FinCen, and arm of the Treasury Department, identifying the entities’ beneficial owners,...more

Greenberg Glusker LLP

Corporate Transparency Act Back in Effect: Updated BOI Compliance Deadlines - Update

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UPDATE as of 3/4/25: As of February 18, 2025, all nationwide injunctions barring the enforcement of the Corporate Transparency Act (the “CTA”) had been lifted. For approximately ten days, the CTA mandatory beneficial...more

Whiteford

Client Alert: CTA Enforcement Suspended – Key Updates on Filing Requirements

Whiteford on

On March 2, 2025, the U.S. Department of the Treasury t (“Treasury”) announced that it will not impose penalties, fines, or pursue enforcement actions against U.S. companies, citizens, or their beneficial owners for failing...more

Pierce Atwood LLP

Out With a Bang: Treasury Restricts Corporate Transparency Act to Foreign Reporting Companies

Pierce Atwood LLP on

On March 2, 2025, the Treasury Department announced suspension of the March 21, 2025 deadline for filing under the Corporate Transparency Act (CTA) for any domestic companies or U.S. citizens....more

White and Williams LLP

Latest Corporate Transparency Act Update from FinCEN: Enforcement Paused, For Now

Stay tuned – another shoe is likely to drop from Washington D.C. on the CTA (“Corporate Transparency Act”) in the next three weeks. As we previously reported on February 18, 2025, the U.S. District Court for the Eastern...more

Greenbaum, Rowe, Smith & Davis LLP

Latest Update on Corporate Transparency Act Compliance: FinCEN Suspends Penalties for Failure to Report by Current Deadlines

In our most recent Alert on the highly controversial and largely litigated nature of the Corporate Transparency Act (CTA), we reported that the CTA was back in effect nationwide and that, but for a few exceptions, all...more

Skadden, Arps, Slate, Meagher & Flom LLP

Europol Published Practical Guide for Cooperation Between Financial Institutions and Investigative Authorities

Public-private partnerships across the world between financial institutions, financial intelligence units and investigative authorities have laid the foundation to advance criminal investigations. However, there is further...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Sanctions: A New Package, Guidance and Legal Clarifications

The future of international sanctions on Russia is not settled. Whilst the representatives of the US and Russia met in Saudi Arabia on 18 February 2025 to discuss possible avenues to peace in Ukraine, the foreign ministers of...more

Pierce Atwood LLP

Corporate Transparency Act Returns: New Deadline March 21, 2025

Pierce Atwood LLP on

Newly Formed Entities Have 30 Days to File - On February 17, 2025, the Eastern District of Texas in Smith v. United States Department of the Treasury lifted the last remaining nationwide preliminary injunction on...more

Greenberg Glusker LLP

Corporate Transparency Act Back in Effect: Updated BOI Compliance Deadlines

Greenberg Glusker LLP on

UPDATE as of 2/20/25: The on-again, off-again Corporate Transparency Act (the “CTA”) mandatory beneficial ownership reporting is now back in effect. On February 18, 2025, the Texas federal district court in Smith v. United...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

Skadden, Arps, Slate, Meagher & Flom LLP

Annual Report Highlights France’s Financial Crime Enforcement and International Cooperation

Ten years after its establishment, France’s National Financial Prosecutor’s Office (Parquet National Financier or PNF) has released its 2024 annual report (Report),1 showcasing a year of consolidation and innovation in the...more

Morrison & Foerster LLP

Off Again, On Again: The CTA Revived

Key Takeaway: Following a court decision on February 18, 2025, the Corporate Transparency Act’s (CTA) beneficial ownership reporting requirements are once again in effect. Most companies will have until Friday, March 21,...more

Foley & Lardner LLP

FinCEN Resumes Corporate Transparency Act Enforcement

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The last remaining nationwide injunction prohibiting enforcement of the Corporate Transparency Act (CTA) has been stayed, clearing the way for the federal government to resume enforcing the CTA. In the case of Smith, et...more

Kerr Russell

The Corporate Transparency’s Act’s Impact on Medical Practices: Understanding Physicians’ Obligations Amid Recent Judicial and...

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Medical practices across the United States are grappling with new compliance obligations under the Corporate Transparency Act (CTA). This article addresses the CTA’s applicability to medical practices, its current legal...more

Cozen O'Connor

U.S. Dials Back Implementation of Foreign Corrupt Practices Act

Cozen O'Connor on

On February 10, 2025, President Trump signed an executive order instructing the Department of Justice (DOJ) and Attorney General (AG) Pamela Bondi to “cease initiation of any new [Foreign Corrupt Practices Act (FCPA) (15...more

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