News & Analysis as of

U.S. Treasury New Guidance FinCEN

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

BCLP

FinCEN Provides Guidance to Reporting Companies in Wake of Second Appeal to Fifth Circuit

BCLP on

As previously reported, the Supreme Court has already considered on an emergency basis whether to stay Corporate Transparency Act (“CTA”) enforcement deadlines. In that case, McHenry v. Texas Top Cop Shop, Inc., No. 24A653,...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

Ballard Spahr LLP on

On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

King & Spalding

OFAC Puts Virtual Currency Industry On Notice

King & Spalding on

Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

K2 Integrity on

Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

Adams & Reese

The Department of Treasury Issues Guidance Regarding Sanctions Risks Inherent to Facilitating Ransomware Payments

Adams & Reese on

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory outlining the risks involved with facilitating ransom payments to malicious actors conducting...more

Holland & Knight LLP

FinCEN Announces National AML/CFT Policy Priorities

Holland & Knight LLP on

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

Perkins Coie

Blockchain Week in Review - April 2021 #3

Perkins Coie on

The Regulation Process for FinCEN’s New Beneficial Ownership Reporting Requirement Launches - The Financial Crimes Enforcement Network (FinCEN) issued an Advanced Notice of Proposed Rulemaking (ANPRM) on Thursday to solicit...more

King & Spalding

Bank Secrecy Act Update

King & Spalding on

Bank Secrecy Act Update: The Financial Crimes Enforcement Network Details Its Bank Secrecy Act Enforcement Approach; Bank Regulators Provide Guidance on Their Approach to BSA Enforcement; FinCEN’s Final Rule Requiring BSA...more

Vinson & Elkins LLP

FinCEN Releases New Guidelines, Highlighting The Factors To Be Considered When Bringing Enforcement Actions

Vinson & Elkins LLP on

In a significant move toward more transparency, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released new guidance (the “Guidance”) on August 18, 2020, setting forth its enforcement approach and...more

Holland & Knight LLP

Treasury Department Issues New Guidance on Hemp Banking

Holland & Knight LLP on

The Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, issued new guidelines on June 29, 2020, for providing banking services to the hemp industry. Hemp that meets the low-THC...more

Eversheds Sutherland (US) LLP

Federal agencies clarify SAR filing requirements for financial services provided to hemp-related businesses

On December 3, 2019, four federal agencies, in consultation with state banking regulators, clarified the legal status of hemp growth and production under the Bank Secrecy Act (BSA) for banks providing financial services to...more

Dorsey & Whitney LLP

Banking Services for Hemp Growers – FinCEN Makes a Statement

Dorsey & Whitney LLP on

On December 3, 2019, FinCEN, along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, in consultation with the Conference of...more

Bradley Arant Boult Cummings LLP

Is the Bank Open? Federal Agencies Clarify Regulatory Requirements for Banking Hemp

On December 3, several federal agencies issued guidance (Guidance) that, by its terms, “provide[s] clarity” regarding “the regulatory requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Spanish

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - October 2018

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Dorsey & Whitney LLP

Clarification From FinCEN — Updating Marijuana Limited SARs

Dorsey & Whitney LLP on

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the Treasury, issued guidance on February 14, 2014 (the “Cannabis Guidance”), to clarify Bank Secrecy Act expectations for financial...more

McDermott Will & Emery

Rapidly Shifting Regulatory Landscape for Virtual Currencies | Market Participants: Stay Tuned

McDermott Will & Emery on

As US regulators have been active in terms of virtual currency regulation, there are three important updates to which attention should be paid. The New York State DFS guidance, the FinCEN letter to Senator Wyden and the...more

Tucker Arensberg, P.C.

Growing Medical Marijuana, Problematic in Bankruptcy, and Out

Tucker Arensberg, P.C. on

Frank Arenas is licensed in Colorado to grow and dispense medical marijuana. He and his wife own a building, half of which is used for the cultivation and the other half of which is leased to a marijuana dispensary. These...more

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