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National Security FinCEN Financial Crimes

Mayer Brown

FinCEN's First Strike: New Section 311 Powers Target Mexican Financial Institutions Under FEND Off Fentanyl Act

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In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more

Mayer Brown

FinCEN Designates Three Mexican Financial Institutions Under New Section 311 Authority: First Use of Expanded Powers Under FEND...

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On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more

Lowenstein Sandler LLP

First Terrorism Indictments Announced Over Drug Cartel Support

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Last Friday, the U.S. Department of Justice (DOJ) unsealed its first indictment against a foreign national for providing material support to a Mexican drug cartel that the current administration recently designated a foreign...more

DLA Piper

Cartels, China, and Fentanyl-Related Illicit Finance

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FinCEN report reveals threat patterns and trends for financial institutions to monitor - The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury (Treasury) published a Financial Trend Analysis...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

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

Ballard Spahr LLP

CTA Reporting Requirements Reinstated With March 21 Deadline for Most Reporting Companies

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As a result of a decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Department of the Treasury on Tuesday, February 18, beneficial ownership information (BOI) reporting requirements under...more

DLA Piper

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

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Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Ballard Spahr LLP

CTA Reporting Requirements Blocked Again

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It’s hard to keep track of the status of reporting obligations under the Corporate Transparency Act (CTA) these days, but in a second ruling during the holiday week, a court blocked the filing requirement again. ...more

Dickinson Wright

Fifth Circuit Reinstates CTA Injunction, FinCEN Still Accepting Voluntary Filings

Dickinson Wright on

In a surprising reversal, on December 26, 2024, a panel of the Fifth Circuit Court of Appeals issued an Order that vacated (effectively reversing) the same court’s order from December 23, 2024, and reinstated a lower court’s...more

Vorys, Sater, Seymour and Pease LLP

CTA UPDATE – Fifth Circuit Reinstates Nationwide Preliminary Injunction

On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Inc., et al. v. Garland,...more

Hinshaw & Culbertson LLP

Yet Another Twist: Fifth Circuit Reinstates Nationwide Freeze on Enforcement of Corporate Transparency Act Filing Deadlines – What...

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Seventy-two hours after a motions panel of the U.S. Court of Appeals for the Fifth Circuit stayed the effect of a nationwide preliminary injunction imposed by a Texas federal district court blocking the reporting deadline for...more

DLA Piper

Fifth Circuit Vacates Stay of Corporate Transparency Act Injunction, Again Putting Deadlines on Hold

DLA Piper on

On December 26, 2024, the US Court of Appeals for the Fifth Circuit vacated the stay entered by a motions panel days earlier, which would have allowed the government to enforce the Corporate Transparency Act (CTA) while it...more

Seyfarth Shaw LLP

The Saga Continues: Fifth Circuit Court Reinstates Nationwide Injunction on CTA Pausing FinCEN’s Recently Announced Reporting...

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The Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury reset Corporate Transparency Act (CTA) reporting deadlines. However, on December 26, 2024, the Fifth Circuit Court of Appeals issued a...more

Pullman & Comley, LLC

Nationwide Injunction Halting Enforcement of CTA Reinstated

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The Fifth Circuit Court of Appeals has reinstated the stay with respect to Corporate Transparency Act (CTA) compliance which means that the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) is...more

Seyfarth Shaw LLP

Fifth Circuit Court Stays Nationwide Injunction on CTA Enforcement - BOI Reporting Requirements Resume

Seyfarth Shaw LLP on

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit issued an order temporarily staying the nationwide preliminary injunction previously granted in Texas Top Cop Shop, Inc., et al. v. Garland, et al. While...more

Dickinson Wright

Fifth Circuit Reverses CTA Injunction, Deadline Extended

Dickinson Wright on

On December 23, 2024, the Fifth Circuit Court of Appeals issued an Order which granted a stay of a lower court’s nationwide injunction against enforcement of the Corporate Transparency Act (CTA or the Act). Texas Top Cop...more

Hinshaw & Culbertson LLP

Fifth Circuit Overturns Preliminary Nationwide Injunction Against Corporate Transparency Act – FinCEN Announces Extension of...

Hinshaw & Culbertson LLP on

On December 23, 2024, a panel of the U.S. Court of Appeals for the Fifth Circuit lifted the preliminary injunction recently imposed by a Texas district court that had blocked the reporting deadline for filing Beneficial...more

Pullman & Comley, LLC

Corporate Transparency Act Enforcement Resumes with Extended Deadlines: January 1, 2025 Deadline Extended to January 13, 2025

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On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the previously issued nationwide injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., which had the effect of reinstating...more

Weintraub Tobin

Court Blocks Nationwide Injunction of the Corporate Transparency Act: Fifth Circuit Grants Stay Pending Appeal; Compliance Period...

Weintraub Tobin on

On December 23, 2024, the Fifth Circuit Court of Appeals granted the government’s emergency motion for a stay, effectively blocking a nationwide injunction issued by a district court against the Corporate Transparency Act...more

DLA Piper

Fifth Circuit Stays Injunction Halting Corporate Transparency Act’s Enforcement; Treasury Updates Deadline to January 13, 2025 for...

DLA Piper on

On December 23, 2024, the US Court of Appeals for the Fifth Circuit issued an order granting the government's emergency motion for a stay pending appeal of the preliminary injunction against the Corporate Transparency Act...more

Ballard Spahr LLP

FinCEN Extends Deadlines in Light of Reinstatement of the CTA

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As noted in our client alert yesterday, the U.S. Court of Appeals for the Fifth Circuit reinstated the enforceability of the Corporate Transparency Act (CTA) and lifted the preliminary injunction issued by the U.S. District...more

Ballard Spahr LLP

U.S. Court of Appeals Reinstates Enforcement of the CTA Nationwide

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On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated the enforceability of the Corporate Transparency Act (CTA), and the preliminary injunction issued by the U.S. District Court for the Eastern...more

Ballard Spahr LLP

Fifth Circuit Halts Nationwide Stay of CTA Enforcement

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The Fifth Circuit has granted the government’s request to stay temporarily the order and injunction issued by the United States District Court for the Eastern District of Texas, which had issued a nationwide stay prohibiting...more

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