News & Analysis as of

U.S. Treasury Department of Justice (DOJ) FinCEN

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

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

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We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more

IR Global

Corporate Transparency Act – Reporting Obligations are Back in Effect

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The Financial Crimes’s Enforcement Network of the U.S. Treasury Department (“FinCEN”) Beneficial Ownership Information (“BOI”) reporting obligations under the Corporate Transparency Act (“CTA”) are once again back in effect....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

A&O Shearman

Cryptocurrency Exchange Pleads Guilty To Violating Anti-Money Laundering Laws, Agrees To Pay More Than $500 Million In Penalties...

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On Monday, February 24, 2025, the U.S. Attorney’s Office for the Southern District of New York (the “SDNY”), in conjunction with the FBI, announced that a Seychelles-based cryptocurrency exchange (“the Exchange”) pled guilty...more

Allen Barron, Inc.

Is it Too Soon for a BOI Report Obituary?

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Is it too soon for a BOI report obituary? After a recent declaration by the U.S. Department of Justice, the FinCEN Beneficial Ownership Interest reporting requirements may be a thing of the past for American companies....more

Orrick, Herrington & Sutcliffe LLP

Treasury suspends enforcement of beneficial ownership information reporting for U.S. companies, focuses on foreign entities

On March 2, the Treasury announced it will suspend enforcement of fines or penalties indefinitely for beneficial ownership information (BOI) reporting. This suspension of enforcement will be for U.S. domestic reporting...more

Akin Gump Strauss Hauer & Feld LLP

Establishment of the Strategic Bitcoin Reserve and United States Digital Asset Stockpile

The Secretary of the Treasury shall establish an office to administer and maintain control of custodial accounts collectively known as the “United States Digital Asset Stockpile,” capitalized with all digital assets owned by...more

Greenbaum, Rowe, Smith & Davis LLP

Another Urgent Update: Corporate Transparency Act is Again Enforceable with New Deadline for Reporting

We previously reported that on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the Fifth Circuit motion panel’s stay of the Corporate Transparency Act (CTA) of the temporary injunction granted by...more

Bracewell LLP

Corporate Transparency Act Reporting Obligations Effective Again With March 21, 2025, Deadline for Most Reporting Companies

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On February 17, 2025, the US District Court for the Eastern District of Texas (EDTX) in Smith, et. al. v. US Department of the Treasury, et. al., entered an order staying the nationwide injunction on enforcement of the...more

McCarter & English, LLP

The Evolution of the CTA: Beneficial Ownership Information Reports Are Due by March 21, 2025

As of February 18, 2025, the US Department of the Treasury Financial Crimes Enforcement Network’s (FinCEN) Corporate Transparency Act (CTA) reporting requirements have been restored—at least temporarily. The new filing...more

Snell & Wilmer

The Corporate Transparency Act: Will the New Deadline to Report Survive?

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On February 17, 2025, the U.S. District Court for the Eastern District of Texas, in Smith, et al. v. U.S. Department of the Treasury, granted the Department of Justice’s request to stay the nationwide injunction that had...more

Ruder Ware

Yo-Yo-Yo: CTA is Back

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The Corporate Transparency Act (CTA) and its reporting requirements are back in effect. This afternoon, a federal district court in Texas granted the U.S. government’s motion to stay (i.e., pause) the nationwide CTA...more

Dorsey & Whitney LLP

U.S. Government Appeals CTA Injunction - But Changes to Reporting Requirements May Be On The Horizon

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As we previously reported, on January 23, 2025, the Supreme Court of the United States ruled in favor of the U.S. government in relation to the Corporate Transparency Act (“CTA”) – granting an emergency application to...more

Kerr Russell

Corporate Transparency Act Enforcement Expected to Resume Following Legal Developments

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While the United States Supreme Court recently lifted one nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Incorporated et al. v. McHenry (formerly Garland),...more

Perkins Coie

What’s in Your (Crypto) Wallet? Trump’s Executive Order on Digital Financial Technology

Perkins Coie on

Last week, President Trump issued an executive order, titled “Strengthening American Leadership in Digital Financial Technology” (EO), establishing the administration’s policy to promote digital asset technologies and the...more

Dickinson Wright

Supreme Court Stays Fifth Circuit CTA Injunction, But Clarity Remains Elusive

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On Jan. 23, 2025, the United States Supreme Court reinstated a stay on the Fifth Circuit Court of Appeals’ Dec. 26, 2024, decision, which had upheld a lower court’s nationwide injunction blocking enforcement of the Corporate...more

Amundsen Davis LLC

Another Twist in the Corporate Transparency Act Saga: FinCEN Announces That Ownership Information Reporting Is Not Currently...

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in an alert posted on its website on January 24, 2025, that reporting companies under the Corporate Transparency Act (CTA) are not...more

Kerr Russell

CTA Enforcement Remains Suspended Amid Ongoing Litigation

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On January 23, 2025, the U.S. Supreme Court granted the U.S. Department of Justice’s request to stay the nationwide injunction that had previously banned enforcement of the Corporate Transparency Act (CTA) and its key...more

Rivkin Radler LLP

The Status of the Corporate Transparency Act – It’s Not Clear

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Few would argue that the federal government does not have a legitimate interest in preventing, detecting, and punishing tax fraud, money laundering, and other financial crimes. Likewise, I imagine few would disagree with the...more

Benesch

FinCEN Confirms Nationwide Pause of Corporate Transparency Act and BOI Reporting Requirements

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Entities should continue preparing to comply with BOI reporting requirements. On December 10, 2024, the Financial Crimes Enforcement Network (FinCEN) alerted businesses that, for now, they do not need to report their...more

McCarter & English, LLP

Corporate Transparency Act: Preliminary Injunction & FinCen’s Response

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The Corporate Transparency Act (31 U.S.C. § 5336, the CTA), which went into effect on January 1, 2024, requires a broad range of corporations, limited liability companies, and other entities (“reporting companies”) to file...more

Epstein Becker & Green

Enforcement of Corporate Transparency Act Halted by Federal Court

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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

Vinson & Elkins LLP

FinCEN’s Response to Nationwide Preliminary Injunction Against Enforcement of the Corporate Transparency Act

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As we previously discussed, on December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

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On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

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