News & Analysis as of

Enforcement Actions FinCEN New Legislation

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

Snell & Wilmer

FinCEN Invokes New 2313a Authority Against Three Mexican Financial Institutions

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On June 25, 2025, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued unprecedented orders under the newly enacted 21 U.S.C. § 2313a authority, targeting three Mexico-based financial institutions:...more

Lowenstein Sandler LLP

Three Banks Targeted by FinCEN in FEND Off Fentanyl Act Actions: What to Know

Lowenstein Sandler LLP on

On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more

Holland & Hart LLP

FinCEN EXEMPTS U.S. Companies and U.S. Persons from CTA Reporting Requirements

Holland & Hart LLP on

The Corporate Transparency Act (together with its implementing regulations, the CTA) is a federal law that went into effect on January 1, 2024. The CTA is aimed at combating financial crimes such as money laundering,...more

Perkins Coie

Corporate Transparency Act: Filing Requirements Once Again Voluntary – FinCEN Announces No Enforcement Action for Reporting...

Perkins Coie on

Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more

Cozen O'Connor

FinCEN Pauses Enforcement Actions under CTA

Cozen O'Connor on

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not take enforcement actions against any companies for failure to file or update beneficial ownership information (BOI) reports...more

Whiteford

Client Alert: Mandatory CTA Compliance Returns – What You Need to Know

Whiteford on

On February 17, 2025, the U.S. District Court for the Eastern District of Texas lifted the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) previously issued in Smith v. US...more

Cozen O'Connor

Latest CTA Injunction Stayed

Cozen O'Connor on

On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction it previously issued in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (Smith case)....more

McNees Wallace & Nurick LLC

Reinstatement of the Corporate Transparency Act Reporting Obligations

Texas Federal Court Reinstates the Corporate Transparency Act The U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., has lifted the “pause” on the Corporate...more

Kerr Russell

CTA Enforcement Reinstated with New Compliance Deadlines

Kerr Russell on

The U.S. District Court for the Eastern District of Texas has stayed the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Smith v. U.S. Department of the Treasury....more

Ruder Ware

It’s Tricky! Tracking the CTA

Ruder Ware on

The Corporate Transparency Act (CTA) remains on hold due to a nationwide injunction granted by a federal District Court in Texas in Smith v. U.S. Department of the Treasury. However, given pending legal battles and...more

Cole Schotz

CTA Update: Companies Not Required To File Under The CTA, Despite Supreme Court Stay

Cole Schotz on

Despite a Supreme Court order issued on January 23, 2025, as of January 24, 2025, FinCEN has stated they are not requiring companies to file under the CTA. On January 23, 2025, the U.S. Supreme Court, in an unsigned order,...more

Ruder Ware

Livin’ on a Stay: The CTA Saga Continues

Ruder Ware on

The Corporate Transparency Act (“CTA”) and its beneficial ownership reporting requirements are back in effect. Earlier today, the U.S. Supreme Court granted the federal government’s request to stay (i.e., pause) the...more

K2 Integrity

State Ballot Wins Only Amplify Questions About Pot Banking

K2 Integrity on

The 2016 election will be remembered not only for the memorable presidential race but also for what was effectively a national referendum on cannabis. Eight states passed laws allowing its use. Medical marijuana is now...more

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