FinCEN report reveals threat patterns and trends for financial institutions to monitor - The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury (Treasury) published a Financial Trend Analysis...more
On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) significantly revising the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency...more
This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more
3/24/2025
/ Anti-Money Laundering ,
Artificial Intelligence ,
Blockchain ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stablecoins
Actions come as Trump Administration hosts digital asset summit, creates bitcoin reserve, and pushes stablecoin legislation - Recent actions by federal agencies and the White House could herald a sea change in US policy...more
3/13/2025
/ Bitcoin ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Executive Orders ,
Federal Reserve ,
FinCEN ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Trump Administration ,
U.S. Treasury
On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more
The Commodity Futures Trading Commission (CFTC, or Commission) has issued an enforcement advisory detailing how its Division of Enforcement (Division) will evaluate self-reporting, cooperation, and remediation from companies...more
3/6/2025
/ CFTC ,
Corporate Governance ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement Actions ,
Enforcement Guidance ,
Financial Regulatory Reform ,
Fraud ,
Mitigation ,
Risk Management ,
Self-Reporting
Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more
2/24/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Immigration and Nationality Act ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Risk Management ,
Trump Administration ,
U.S. Treasury
This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more
2/21/2025
/ Blockchain ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Popular ,
Regulatory Agenda ,
Regulatory Reform ,
Securities and Exchange Commission (SEC)
On February 17, 2025, the US District Court for the Eastern District of Texas stayed its previous order suspending enforcement of the Corporate Transparency Act (CTA)’s Reporting Rule in Smith v. US Dept. of the Treasury,...more
The US Department of Justice (DOJ)’s Attorney General, Pam Bondi, recently released over a dozen memoranda on a variety of policies – ranging from plea agreements and sentencing criteria, to the DOJ’s amplified focus on...more
2/10/2025
/ Anti-Money Laundering ,
Cartels ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Institutions ,
Joint Task Force ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Terrorism Funding ,
Trump Administration
The US Department of Justice (DOJ) has announced that Wall Street Exchange (WSE), a Dubai-based money exchange service provider, entered into a non-prosecution agreement (NPA) and agreed to pay more than $9.2 million to...more
2/5/2025
/ Anti-Money Laundering ,
Bank Fraud ,
BSA/AML ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
Foreign Entities ,
Money Laundering ,
Money Transmitter ,
Non-Prosecution Agreements ,
Settlement ,
White Collar Crimes
This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more
1/28/2025
/ Blockchain ,
CFTC ,
Chattel ,
Commodities ,
Consumer Financial Products ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Financial Services Industry ,
IRS ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Smart Contracts ,
Virtual Currency
On January 23, 2025, the Supreme Court of the United States granted the federal government a stay of the preliminary injunction foreclosing enforcement of the Corporate Transparency Act (CTA) in McHenry v. Texas Top Cop Shop,...more
1/27/2025
/ Appeals ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Enforcement Actions ,
Financial Crimes ,
FinCEN ,
Garland v Texas Top Cop Shop ,
McHenry v Texas Top Cop Shop ,
Money Laundering ,
Preliminary Injunctions ,
SCOTUS
Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more
1/27/2025
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Enforcement Actions ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Investment ,
National Security ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On December 26, 2024, the US Court of Appeals for the Fifth Circuit vacated the stay entered by a motions panel days earlier, which would have allowed the government to enforce the Corporate Transparency Act (CTA) while it...more
12/30/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Vacated
On December 23, 2024, the US Court of Appeals for the Fifth Circuit issued an order granting the government's emergency motion for a stay pending appeal of the preliminary injunction against the Corporate Transparency Act...more
12/24/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more
12/23/2024
/ Blockchain ,
CFTC ,
Commodities ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Financial Instruments ,
Financial Services Industry ,
FinTech ,
FSOC ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Regulatory Agenda ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
SIFMA
Congress passed the Corporate Transparency Act (CTA) as an anti-money laundering initiative in 2021 designed to combat the use of anonymous “shell companies” to facilitate money laundering, terrorist financing, and threaten...more
12/6/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more
12/6/2024
/ AML/CFT ,
Anti-Money Laundering ,
Broker-Dealer ,
Enforcement Actions ,
Enforcement Statistics ,
Financial Markets ,
FinCEN ,
Investment ,
Investment Adviser ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations ,
Suspicious Activity Reports (SARs)
Time is running out for Corporate Transparency Act (CTA) compliance. The law, which became effective on January 1, 2024, requires certain entities – or “reporting companies” – to disclose information about their beneficial...more
12/2/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Deadlines ,
Financial Crimes ,
FinCEN ,
National Security ,
Regulatory Requirements ,
Reporting Requirements
Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more
9/5/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Compliance ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
National Security ,
Private Funds ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Terrorism Funding
On May 13, 2024, the Securities and Exchange Commission (SEC) and the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly proposed a new rule that would impose requirements on SEC-registered...more