News & Analysis as of

Reporting Requirements Enforcement Actions Financial Crimes

WilmerHale

DOJ Antitrust Announces New Whistleblower Program

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On July 8, 2025, the Department of Justice, Antitrust Division (“Antitrust Division”) announced that it is creating the Antitrust Whistleblower Rewards Program (the “Whistleblower Program”) in partnership with the U.S. Postal...more

Morrison & Foerster LLP

Show Them the Money: New Rewards Program Heightens Incentives for Antitrust Whistleblowers

On July 8, 2025, the Department of Justice Antitrust Division (the Division) announced a new program that could provide monetary payouts to individuals who report criminal antitrust violations. The program, described in a...more

Troutman Pepper Locke

In Response to the President’s Directive, CFPB Unveils New Strategy to Tackle Criminal Regulatory Offenses

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Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in...more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

K&L Gates LLP

Key Compliance Tips on How to Respond to Information Requests From OFSI

K&L Gates LLP on

On 8 May 2025, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of HM Treasury published a penalty notice regarding a breach of financial sanctions by a UK registered company—Svarog Shipping & Trading...more

Morrison & Foerster LLP

CFTC Advisory Outlines Materiality Criteria for Enforcement Referrals

On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more

Mayer Brown

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

Mayer Brown on

On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

A&O Shearman

UK Financial Intelligence Unit SARS report published

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The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...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

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels

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

Buchalter

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

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On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

Kohrman Jackson & Krantz LLP

The Treasury Department Introduces a New Twist in the CTA Saga

On March 2, 2025, the U.S. Department of Treasury threw a new twist into the ongoing Corporate Transparency Act (CTA) enforcement saga by announcing that it will not enforce any fines or penalties against any U.S. citizens or...more

Proskauer - Regulatory & Compliance

Ping-Pong Match Appears Over: US Companies Apparently Definitively Relieved of Compliance Obligations Under the Corporate...

The Corporate Transparency Act (the CTA) requires a range of entities, primarily smaller, unregulated companies, to file reports with FinCen, and arm of the Treasury Department, identifying the entities’ beneficial owners,...more

White and Williams LLP

Latest Corporate Transparency Act Update from FinCEN: Enforcement Paused, For Now

Stay tuned – another shoe is likely to drop from Washington D.C. on the CTA (“Corporate Transparency Act”) in the next three weeks. As we previously reported on February 18, 2025, the U.S. District Court for the Eastern...more

Shumaker, Loop & Kendrick, LLP

Client Alert: The Treasury Department Announces It Will Not Issue Fines or Penalties in Connection with Beneficial Ownership...

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced 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...more

Pierce Atwood LLP

Corporate Transparency Act Returns: New Deadline March 21, 2025

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Newly Formed Entities Have 30 Days to File - On February 17, 2025, the Eastern District of Texas in Smith v. United States Department of the Treasury lifted the last remaining nationwide preliminary injunction on...more

UB Greensfelder LLP

What the Latest Reinstatement of the Corporate Transparency Act Means

UB Greensfelder LLP on

Filing requirements under the Corporate Transparency Act (CTA) have been reinstated. Per FinCEN’s (Financial Crimes Enforcement Network’s) most recent Alert released on February 18, 2025, the new deadline for filing...more

Cozen O'Connor

Latest CTA Injunction Stayed

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On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction it previously issued in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (Smith case)....more

McDermott Will & Schulte

Corporate Transparency Act Update: Reporting Obligations Reinstated

On February 18, 2025, the US District Court for the Eastern District of Texas in Smith v. US Department of the Treasury, No. 6:24-cv-336-JDK, entered an order staying (pausing) the nationwide preliminary injunction against...more

Kerr Russell

CTA Enforcement Reinstated with New Compliance Deadlines

Kerr Russell on

The U.S. District Court for the Eastern District of Texas has stayed the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Smith v. U.S. Department of the Treasury....more

Vinson & Elkins LLP

Supreme Court Grants Stay of Preliminary Injunction Against Corporate Transparency Act – Second Injunction Still In Effect

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On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more

McDermott Will & Schulte

Corporate Transparency Act Update: Nationwide Injunction Continues

On January 23, 2025, the Supreme Court of the United States issued a stay of the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) (31 U.S.C. § 5336) and the Beneficial Ownership...more

Kohrman Jackson & Krantz LLP

CTA Reporting Remains Voluntary Despite Recent Supreme Court Decision

On January 23, 2025, the U.S. Supreme Court stayed a nationwide preliminary injunction issued in Texas Top Cop Shop, Inc. et al. v. Garland et al., creating further legal uncertainty surrounding the Corporate Transparency Act...more

Farella Braun + Martel LLP

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

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

Sheppard Mullin Richter & Hampton LLP

FDIC Enforcement Spotlights Deficiencies in Kansas Bank’s Anti-Money Laundering Program

On December 27, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a notice of assessment of a civil money penalty against a Kansas-based bank. The action, originally brought in November, imposed a $20.4 million...more

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