News & Analysis as of August 3, 2025

Enforcement

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

The (Almost) End of the Corporate Transparency Act

Snell & Wilmer on 4/14/2025

In a whirlwind attempt to follow the roller coaster actions in the courts, the U.S. Congress, and FinCEN’s administrative efforts, Snell & Wilmer has worked to keep clients updated with the drama-filled developments of the...more

U.S. Supreme Court Provisionally Reinstates the Corporate Transparency Act

Amundsen Davis LLC on 1/24/2025

The U.S. Supreme Court issued an order on January 23, 2025, which provisionally reinstates the Corporate Transparency Act (CTA) while a legal challenge to it continues. This brief order, which stayed an injunction against the...more

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

Farella Braun + Martel LLP on 1/15/2025

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Update: The Corporate Transparency Act Put On Hold

Rothwell, Figg, Ernst & Manbeck, P.C. on 12/20/2024

As an update to our post on the Corporate Transparency Act, on December 3, 2024, a federal district court issued a nationwide preliminary injunction pertaining to the Corporate Transparency Act in Texas Top Cop Shop, Inc. v....more

Is the Corporate Transparency Act Going To Be Brought Back to Life?

Snell & Wilmer on 12/12/2024

On December 5, 2024, the Department of Justice (DOJ), filed a Notice of Appeal in response to a U.S. District Court’s recently issued, nationwide preliminary injunction stopping the reporting obligations under the Corporate...more

Federal Court Suspends Enforcement of the Corporate Transparency Act’s Reporting Requirements

White and Williams LLP on 12/10/2024

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction prohibiting the federal government from enforcing the Corporate Transparency Act (the “CTA”) nationwide. Texas Top...more

What Does the Nationwide Preliminary Injunction of the Corporate Transparency Act Mean for Businesses?

Holland & Hart LLP on 12/6/2024

On December 3, 2024, the U.S. District Court for the Eastern District of Texas granted a nationwide preliminary injunction barring enforcement of the Corporate Transparency Act (CTA)1 and its key implementing regulations...more

The Corporate Transparency Act – Is it on Life Support?

Snell & Wilmer on 12/6/2024

In Texas Top Cop Shop, Inc. et al. v. Merrick Garland, a U.S. District Court in Texas has issued a potentially major setback to the continued application of the Corporate Transparency Act (CTA), which became effective on...more

Nationwide Preliminary Injunction Issued Barring Enforcement of the CTA

ArentFox Schiff on 12/5/2024

On December 3, the US District Court for the Eastern District of Texas issued a nationwide preliminary injunction barring the enforcement by the US government of the Corporate Transparency Act (CTA)....more

Federal Court Halts Enforcement of Corporate Transparency Act Nationwide: Recommended Steps for Businesses

Kohrman Jackson & Krantz LLP on 12/5/2024

On December 3, 2024, a Texas federal district court issued a nationwide preliminary injunction temporarily blocking the enforcement of the Corporate Transparency Act (CTA) and its requirement to report the beneficial owners...more

Nationwide Injunction Pauses Enforcement of the Corporate Transparency Act

Davis Wright Tremaine LLP on 12/5/2024

On December 3, 2024, a federal court issued a nationwide preliminary injunction blocking the enforcement of the Corporate Transparency Act (CTA). This injunction creates uncertainty ahead of the CTA's January 1, 2025,...more

Corporate Transparency Act: Client Alert Update

Sullivan & Worcester on 12/3/2024

As we enter December, the deadline for existing non-exempt entities to comply with the Corporate Transparency Act (CTA) is fast approaching. Entities that were formed or registered to do business in the United States prior to...more

Enforcement News: Broker-Dealers Settle Charges for Filing Deficient SARs

Freiberger Haber LLP on 12/3/2024

The Bank Secrecy Act (“BSA”) and implementing regulations promulgated by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) require that broker-dealers file a suspicious activity report (SAR”) with...more

How Compliance Teams Can Think About Risk in Modern Times

NAVEX on 11/27/2024

A few weeks back the U.S. Financial Crimes Enforcement Network (FinCEN) published a bulletin urging financial firms to do better at identifying deepfakes that fraudsters might use to evade customer due diligence programs. The...more

Corporate Transparency Act: The Time to File is Now

Gibney Anthony & Flaherty, LLP on 11/25/2024

If you have a small company in the U.S. with less than 20 employees, you need to be aware of a new law that directly impacts your business. The Corporate Transparency Act (the “CTA”) requires you to provide information to the...more

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on 10/24/2024

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

American Conference Institute (ACI) on 9/25/2024

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

K&L Gates LLP on 6/27/2024

Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

Bracewell LLP on 1/12/2024

2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

Navigating U.S. Sanctions and Export Control Restrictions

American Conference Institute (ACI) on 11/14/2023

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

Voluntary Self-Disclosure: Is the Value Self-Evident?

Pillsbury Winthrop Shaw Pittman LLP on 8/4/2023

How should companies think about DOJ, BIS and OFAC voluntary disclosure in the wake of the DOJ’s massive investment in sanctions and export control enforcement? The DOJ, BIS and OFAC released a joint compliance note...more

Tri-Seal Compliance Note Encourages Voluntary Self-Disclosure of Potential Violations of Sanctions and Export Control Laws to DOJ,...

Seward & Kissel LLP on 8/2/2023

The ascending importance of rigorous and compliance with U.S. national security laws, including sanctions and export controls, was underscored on July 26, 2023 with the release of a Department of Commerce, Department of the...more

U.S. Authorities Amplify Enforcement Efforts to Address Financial Crime Risks in the Digital Asset Industry

K2 Integrity on 10/26/2022

The United States Department of the Treasury has continued to signal that it will focus policy, regulatory, and enforcement attention on the financial crime and sanctions risk in the crypto and digital asset ecosystem...more

Top PHive Crypto Enforcement Notes: September Edition

Paul Hastings LLP on 9/7/2022

Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more

Crypto, CBDC and Blockchain Supply Chain Initiatives Announced; More SEC and FinCEN Enforcement; Crypto Tax Amendment Fails; DeFi...

BakerHostetler on 8/16/2021

Crypto Firms Pursue Bank Charters, Traditional Financial Firms Integrate Crypto - This week, the Wyoming Division of Banking granted a new Special Purpose Depository Institution (SPDI) bank charter to Commercium Financial...more

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