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Penalties FinCEN Enforcement Actions

Cadwalader, Wickersham & Taft LLP

Midyear Momentum, July 2025 - FinCEN Uses the FEND Off Fentanyl Act for First Time To Prohibit Funds Transfers With Three Mexican...

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

Hogan Lovells

FinCEN invokes new Section 2313a authority against three Mexican financial institutions: The who, what, when, where, why, and...

Hogan Lovells on

The orders represent the first use of new authorities by FinCEN. U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions will be subject to significant compliance obligations,...more

Brownstein Hyatt Farber Schreck

Recent Enforcement Actions a Reminder of the Importance of BSA Compliance for Nevada Casinos

Following a multiyear lull, the Nevada gaming industry has recently experienced a flurry of federal and state regulatory actions related to the enforcement of the Bank Secrecy Act. Just the past several months alone have seen...more

Coblentz Patch Duffy & Bass

CTA/BOI Update - Treasury Department Announces Suspension of Enforcement for Domestic Entities

On February 27, 2025, FinCEN announced that it would not issue fines or penalties or take any other enforcement action against any companies based on any failure to file or update beneficial ownership information (BOI)...more

Schwabe, Williamson & Wyatt PC

Treasury Pauses Penalties for Corporate Transparency Act

On March 2, 2025, the U.S. Treasury Department announced that it currently does not intend to enforce any penalties or fines associated with any current reporting deadlines under the Corporate Transparency Act (CTA) or the...more

Butler Snow LLP

Treasury Department Limits Enforcement of the Corporate Transparency Act

Butler Snow LLP on

The Treasury Department announced on March 2nd that it does not intend to enforce any penalties or fines against either U.S. citizens or domestic reporting companies and their beneficial owners under the Corporate...more

Seward & Kissel LLP

Treasury Department Confirms: No Fines or Penalties in Connection with BOI Reporting Deadlines

Seward & Kissel LLP on

While the March 21, 2025 filing deadline under the Corporate Transparency Act (the “CTA”) remains in place, the Treasury Department announced on March 2nd that it will not enforce any penalties or fines associated with...more

Moritt Hock & Hamroff LLP

The Treasury Department Announces Suspension Of Enforcement Of Corporate Transparency Act Against U.S. Citizens & Domestic...

In a significant development, on March 2, 2025, the U.S. Department of the Treasury (the “Treasury Department”) announced that, not only will the Treasury Department not enforce any penalties or fines associated with the...more

Neal, Gerber & Eisenberg LLP

Treasury Limits CTA Enforcement to Foreign Companies

On March 2, 2025, the Treasury Department expanded the scope of FinCEN’s February 27, 2025 statement that it will not enforce any penalties or fines under the Corporate Transparency Act with respect to existing regulatory...more

Snell & Wilmer

The Corporate Transparency Act Update: A Reprieve for American Businesses?

Snell & Wilmer on

In another twist as to the future of the Corporate Transparency Act’s (CTA) implementation and judicial intervention, on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not be...more

Bowditch & Dewey

Corporate Transparency Act – Yes, it’s Back, but no Fines or Penalties for Now

Bowditch & Dewey on

On February 27, 2025, in a move to comply with the Treasury’s commitment to reducing regulatory burdens on businesses, FinCEN announced that it will not impose fines or penalties or take other enforcement actions against any...more

Katten Muchin Rosenman LLP

CTA Is Pausing Fines, Penalties and Enforcement Actions Regarding Filing of Beneficial Ownership Information Reports

Below is a statement from the Financial Crimes Enforcement Network (FinCEN) released February 27, 2025 stating it will not take any enforcement action against a Reporting Company that fails to file or update a beneficial...more

Greenbaum, Rowe, Smith & Davis LLP

Latest Update on Corporate Transparency Act Compliance: FinCEN Suspends Penalties for Failure to Report by Current Deadlines

In our most recent Alert on the highly controversial and largely litigated nature of the Corporate Transparency Act (CTA), we reported that the CTA was back in effect nationwide and that, but for a few exceptions, all...more

Foley & Lardner LLP

FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines for Now

Foley & Lardner LLP on

FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the...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

Hinshaw & Culbertson LLP

URGENT UPDATE: Corporate Transparency Act Reporting Requirements Back in Effect – What You Need To Know

Companies are once again required to comply with the CTA and its reporting obligations. As discussed in our previous update, last month the Supreme Court of the United States (SCOTUS) stayed (i.e., suspended the effect of)...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect

Fox Rothschild LLP on

The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Kerr Russell

The Corporate Transparency’s Act’s Impact on Medical Practices: Understanding Physicians’ Obligations Amid Recent Judicial and...

Kerr Russell on

Medical practices across the United States are grappling with new compliance obligations under the Corporate Transparency Act (CTA). This article addresses the CTA’s applicability to medical practices, its current legal...more

White & Case LLP

SEC Charges Investment Adviser - Signaling Importance of Accurate Disclosure of AML Procedures

White & Case LLP on

The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures. As we...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

Mintz - Venture Capital & Emerging Companies...

Compliance with the New York LLC Transparency Act Necessary for Many Mintz Clients

Clients with Limited Liability Companies in New York Likely Impacted - New York Governor Kathy Hochul recently signed the New York LLC Transparency Act (NYLTA) into law. The act, which will become effective on December 21,...more

Bass, Berry & Sims PLC

The Corporate Transparency Act: A Primer for “Small” Businesses

Bass, Berry & Sims PLC on

The Corporate Transparency Act (CTA), which aims to curb illicit financial activities like money laundering and other fraudulent activities, will go into effect on January 1, 2024. Consequentially, many types of businesses,...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $200 Million in Penalties for BSA-AML Violations

On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $9 Million in Penalties for BSA-AML Violations

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) and the Financial Crimes Enforcement Network (“FinCEN”) issued civil monetary penalties against a Texas community bank for violations of the Bank...more

The Volkov Law Group

UBS Pays $15 Million for AML Compliance Deficiencies

The Volkov Law Group on

UBS Group agreed to pay a combined $15 million penalty to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”)and the SEC for regulatory deficiencies in its anti-money laundering compliance program. ...more

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