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Enforcement Priorities FinCEN

Foley & Lardner LLP

U.S. FinCEN's Order Targeting CIBanco Will Upend Mexican Fiduciary Market

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In late June 2025, the U.S. Treasury’s FinCEN (Financial Crimes Enforcement Network), under new authorities granted pursuant to the Fentanyl Sanctions Act, the FEND Off Fentanyl Act, and in line with President Trump’s...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

Holland & Knight LLP

Corporate Transparency Act Interim Final Rule Issued

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In the latest development of the ongoing Corporate Transparency Act (CTA) saga, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 21, 2025, issued an interim final rule that...more

Bradley Arant Boult Cummings LLP

How the Trump Administration’s War on Cartels Will Reshape the Financial Sector

On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more

Ballard Spahr LLP

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

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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

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: Injuction Lifted - Corporate Transparency Act Back in Effect

On February 17, a federal judge in Texas lifted a preliminary injunction issued in Smith v. United States Department of the Treasury, removing the last legal hurdle to the enforcement of the Corporate Transparency Act...more

Holland & Knight LLP

Ringing the (Jingle) Bell: Whistleblower Program 2024 Recap

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Whistleblower programs are the gifts that keep giving to enforcement agencies, driving a record number of cases, sanctions and awards across multiple agencies. In this ninth installment of Season's Readings, we revisit some...more

Morris, Manning & Martin, LLP

Securities & Corporate Governance Q4 2024 Quarterly Newsletter

Morris, Manning & Martin, LLP’s Securities & Corporate Governance Quarterly Newsletter is designed to update public and private company clients on recent developments in federal securities laws and corporate governance...more

Latham & Watkins LLP

Recent Developments for Directors - April 2024 Edition

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SEC Wins “Shadow Trading” Case - The SEC notched a major win in its recent Panuwat case, described as the first-ever “shadow trading” enforcement action. After a biotech executive learned about his company’s imminent...more

Dorsey & Whitney LLP

DOJ to Develop New Whistleblower Program to Augment Existing Federal Whistleblower Programs

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Last week Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (DOJ) will soon begin a pilot program to reward whistleblowers who alert prosecutors to significant corporate misconduct. The goal of...more

Goodwin

Navigating the Hazy Landscape: Challenges and Solutions in Cannabis Payment Processing

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The sale of adult-use cannabis has been legalized in 24 states in the United States. But this does not mean there are no other legal impediments to the cannabis industry in those jurisdictions. For example, cannabis...more

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

Dorsey & Whitney LLP

U.S. Treasury Department Takes Action Against Russian Darkmarket Entity as Latest Government Move Against Cybercrime

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On April 5, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) in the U.S. Department of the Treasury named Genesis Market to OFAC’s Specially Designated Nationals List (“SDN List”). Genesis Market is...more

BakerHostetler

Crypto Payment Products, DeFi Networks and Price Indices Launch; CBDC Report and NFT Royalty Data Published; FinCEN, FTC Address...

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Payments Firms Launch Crypto Products, New DeFi Price Indices Announced - A U.S. fintech company recently announced the launch of a fiat-to-crypto on-ramp, which facilitates fiat-to-crypto payments using “a customizable...more

Holland & Knight LLP

Red Flag Refresher: Broker-Dealers and the Importance of Strong AML Compliance

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The SEC continues to focus a portion of its enforcement attention on registrants' obligations with regard to anti-money laundering (AML) compliance and transaction monitoring. In this post, we provide a refresher on the...more

BCLP

SEC Continues Focus on Insider Trading by Securities Industry Participants

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Insider trading is a front-and-center issue for the SEC, and consequently must be for financial services firms as well. The SEC included misuse of material non-public information (MNPI) on its list of 2022 exam priorities for...more

BakerHostetler

Banks and Retailers Embrace Crypto, Bitcoin Environmental Costs Debated, New NFT Initiatives Launch, Various Agencies Address...

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According to reports, a major U.S.-based global investment bank has allowed a borrower to use bitcoin as collateral for a cash loan, for the first time in the bank’s history. In other financial news, according to reports, the...more

Jones Day

FinCEN Warns Institutions of Sanctions Evasion Risks

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As the U.S. government's economic sanctions against Russia continue to grow, regulators are calling on financial institutions to help detect and prevent attempts to evade these measures through the use of convertible virtual...more

BCLP

Continuing AML regulatory issue focus: A look at a recent SEC enforcement case, the SEC’s response to Petition for Certiorari, and...

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Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more

BCLP

Compliance Impact of FinCEN Statement of Priorities

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At the direction of the President, FinCEN is intensifying its regulation of banks and fintechs across the spectrum of the laws that it is charged with enforcing. This past June, the White House published the Memorandum on...more

WilmerHale

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

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The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Eversheds Sutherland (US) LLP

FinCEN on fire: Rapid release of AML Act updates

On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) provided an update on implementation of the Anti-Money Laundering Act of 2020 (AML Act) and issued the first government-wide priorities for anti-money...more

BCLP

Sharper Lines Mean Tighter Nets: How the FinCEN’s Latest Priorities are Another Step to Increased Enforcement

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In the latest sign that the federal enforcement apparatus is slowly but surely training its sights on white-collar professionals and businesses, particularly financial services, the Financial Crimes Enforcement Network...more

Holland & Knight LLP

FinCEN Announces National AML/CFT Policy Priorities

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The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

Herbert Smith Freehills Kramer

DOJ Cyber-Digital Task Force Releases Cryptocurrency Enforcement Framework

Building off a 2018 alert outlining cyber threats generally, and following the federal indictment for money laundering of the founders of the offshore cryptocurrency exchange BitMEX, on Oct. 8, 2020, the U.S. Department of...more

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