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U.S. Treasury Anti-Corruption

Thomas Fox - Compliance Evangelist

2 Gurus Talk Compliance: Episode 48 – The March Madness Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more

Thomas Fox - Compliance Evangelist

All Things Investigations: Terrorism Designations of Mexican Cartels Fundamentally Enhances Risk for All Companies

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by Jeremy Paner and Diego Durán de la Vega to discuss the...more

The Volkov Law Group

FCPA Predictions: Don’t Expect Much to Change

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In 2017, when President Trump first took office, big changes were expected in FCPA enforcement.  Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA.  He was not a big fan of the law and...more

The Volkov Law Group

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

The Volkov Law Group on

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more

Shumaker, Loop & Kendrick, LLP

Client Alert: Reporting Companies Once Again Required to Report Ownership Information to FinCEN

In light of a December 23, 2024, federal Court of Appeals decision, reporting companies, except as indicated below, are once again required to file beneficial ownership information with the Financial Crimes Enforcement...more

Epstein Becker & Green

Enforcement of Corporate Transparency Act Halted by Federal Court

Epstein Becker & Green on

Following the decision of a federal court on December 3, 2024, enjoining enforcement of the Corporate Transparency Act (the “Act”), FinCEN announced last week that reporting companies are not currently required to file...more

Whiteford

Client Alert: DOJ and OFAC Actions Showcase Expansive U.S. Oversight of Foreign Conduct

Whiteford on

The U.S. Department of Justice (DOJ) and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) have recently announced two enforcement actions that demonstrate the U.S. government's aggressive and...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

Whiteford on

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

Polsinelli on

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

Holland & Knight LLP

FinCEN Issues Final Rule Implementing Access and Safeguard Provisions of the CTA

Holland & Knight LLP on

The Corporate Transparency Act (CTA) was enacted in 2021 and became effective on Jan. 1, 2024. The CTA was passed with the aim of enhancing transparency in corporate ownership, so as to combat the proliferation of anonymous...more

BakerHostetler

Treasury Revisits Past Rulemaking to Bring Investment Advisers Under AML Oversight

BakerHostetler on

In connection with the Biden Administration’s ongoing crackdown on corruption, tax havens, and illicit financing, on December 11, Treasury released a Fact Sheet on its “efforts to address the illicit finance and national...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

Polsinelli

Part 4: Addressing and Demystifying Common Denials Surrounding the Upcoming CTA

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CTA Denial #4: “That can’t be constitutional.” A lone small business advocacy group, National Small Business United (affiliated with the National Small Business Association), has filed suit against the U.S. Department of...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - October 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Akin Gump Strauss Hauer & Feld LLP

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

Akerman LLP on

On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

Skadden, Arps, Slate, Meagher & Flom LLP

New US Efforts To Prosecute Sanctions Evasion and Export Control Violations May Require Compliance Programs To Be Updated

DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more

Cadwalader, Wickersham & Taft LLP

Tri-Seal Compliance Note Warns of Sanctions Evasion

On March 2, the Department of Commerce, Department of Justice, and Department of the Treasury issued a Tri-Seal Compliance Note warning companies to be vigilant for Russia-related sanctions evasion. The Note sets forth a...more

The Volkov Law Group

DOJ, and Departments of Commerce and Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls

The Volkov Law Group on

As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

Hogan Lovells

Treasury Department issues inter-agency business advisory on Burma

Hogan Lovells on

On January 26, 2022, the U.S. Department of the Treasury issued an advisory for businesses and individuals doing business in Burma. Specifically, the business advisory cautions business and individuals to be aware of exposure...more

Lowenstein Sandler LLP

Trade Matters, January 2022: A monthly newsletter covering global trade & national security developments

1. New Import Ban on All Products From China’s Xinjiang Region- In late December 2021, President Biden signed the Uyghur Forced Labor Prevention Act into law. The new legislation creates a rebuttable presumption that any...more

Lowenstein Sandler LLP

Trade Matters - July 2021

1. Chinese Trade Tensions Ramp Up- On June 3, President Joe Biden signed Executive Order 14032, replacing and superseding previous EOs that banned U.S. persons from purchasing and selling public securities of Chinese...more

Holland & Knight LLP

FinCEN Announces National AML/CFT Policy Priorities

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The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

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