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National Security Anti-Money Laundering U.S. Treasury

ArentFox Schiff

GENIUS Act Ushers in New Era for US Stablecoin Regulation and Digital Asset Leadership

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On July 18, President Trump signed the GENIUS Act into law, marking a significant development in the regulation of digital assets and stablecoins in the United States....more

Morrison & Foerster LLP

FinCEN Targets Three Mexico-Based Financial Institutions with Sanctions Under New Authority to Address Money Laundering Associated...

On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more

Orrick, Herrington & Sutcliffe LLP

Senators pen bipartisan letter arguing rescission of Treasury rule

On May 27, Sens. Sheldon Whitehouse (D-RI) and Charles Grassley (R-IA) wrote to the Treasury encouraging recission of the interim final rule requiring “foreign reporting companies,” but not domestic entities or U.S. citizens,...more

Holland & Knight LLP

Mexico Creates Specialized General Agency on Criminal Organizations

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Mexico's Official Gazette of the Federation (Diario Oficial de la Federación) published a decree to reform and add provisions to the Internal Regulations of the Ministry of Finance and Public Credit (SHCP), establishing the...more

Troutman Pepper Locke

The GENIUS Act Advances in the Senate

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The U.S. Senate’s proposal to regulate stablecoins, known as the GENIUS Act, has successfully cleared a significant procedural hurdle, moving closer to a full floor debate. On May 19, lawmakers voted to invoke cloture on the...more

Morgan Lewis

US Designation of Cartels as Terrorist Organizations Increases Risk of Doing Business in Mexico

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Recent US government actions indicate a possible increase in US financial crimes investigations and enforcement targeting drug cartels and transnational criminal organizations in Latin America....more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...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

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

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

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The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

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On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

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Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more

Wilson Sonsini Goodrich & Rosati

The Corporate Transparency Act is Back On–Again!

On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted the federal government’s motion for a stay pending appeal and lifted the nationwide preliminary injunction in Smith, et al. v. U.S....more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Sheppard Mullin Richter & Hampton LLP

The Return of the CTA: FinCEN Confirms that Beneficial Ownership Information Reporting Requirements are Back in Effect with a New...

On February 19, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that beneficial ownership information reporting requirements under the Corporate Transparency Act (“CTA”) are back in effect with a new...more

Baker Botts L.L.P.

Compliance, Enforcement, and Litigation Risk Considerations from President Trump’s Executive Order on Designating New Foreign...

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On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The order directs the...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

Paul Hastings LLP

Implications for Mexican Banks and Financial Institutions of President Trump’s Designation of Drug Cartels as Foreign Terrorist...

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On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more

Cadwalader, Wickersham & Taft LLP

Court Finds Corporate Transparency Act Unconstitutional and Unenforceable as to NSBA Members

On March 1, 2024, the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (“CTA”) is unconstitutional. The CTA requires many U.S. entities to disclose their individual beneficial...more

Whiteford

Client Alert: Corporate Transparency Act (CTA) Found Unconstitutional by Federal District Court

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On March 1, 2024, the U.S. District Court for the Northern District of Alabama in National Small Business United et al.  v. Janet Yellen et. al., Case No. 5:22-cv-1448-LCB,  held the Corporate Transparency Act (the “CTA”) to...more

Polsinelli

Challenge to Corporate Transparency Act Prevails – For Now

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On March 1, 2024, a U.S. District Judge in Alabama issued a judgment holding that the Corporate Transparency Act (CTA) is unconstitutional because it exceeds the Constitution’s limits on Congress’ power. Further, FinCEN is...more

White & Case LLP

FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs

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On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more

Proskauer - Regulatory & Compliance

CTA – Accessing Beneficial Ownership Information

On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final rule on Beneficial Ownership Information Access and Safeguards (the “Access Rule”) laying out the...more

Husch Blackwell LLP

Corporate Transparency Act Guide

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On January 1, 2024, the Corporate Transparency Act (CTA) will go into effect, and if your business is deemed to be a Reporting Company under the CTA, the clock will begin ticking on new federal reporting obligations....more

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