On March 21, 2025, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) narrowed the scope of the beneficial ownership information (“BOI”) filing requirement under the Corporate Transparency Act...more
FinCEN announced that by March 21, 2025, it plans to issue an interim final rule that will extend the current beneficial ownership information (BOI) reporting deadlines under the Corporate Transparency Act. Until the new rule...more
The Corporate Transparency Act (CTA) is back in effect − at least for now − and companies covered by the CTA are once again required to file beneficial ownership information (BOI) reports with FinCEN. On February 17, 2025, in...more
On January 23, 2025, the U.S. Supreme Court vacated one nationwide stay (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland) which blocked the U.S. government from enforcing the Corporate...more
A federal judge has blocked the U.S. government from enforcing the Corporate Transparency Act (CTA) and its implementing regulations nationwide. As a result, companies affected by the CTA do not have to report information...more
The deadline is quickly approaching for companies created or registered to do business in the United States before 2024 to report beneficial ownership information as required by the Corporate Transparency Act (CTA). The CTA...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule to counter money laundering and the financing of terrorism that would add significant compliance requirements for financial...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Access Rule) regarding access to and use of beneficial ownership information (BOI) maintained by FinCEN....more
The Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) issued a Notice of Proposed Rulemaking (the “Proposed Access Rule”) on December 15, 2022 to implement the second key provision of the...more
This fall the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published a final rule (the “Rule”), effective January 1, 2024, to implement beneficial ownership reporting requirements included in the...more
The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more
4/27/2022
/ Bribery ,
BSA/AML ,
Cryptocurrency ,
Economic Sanctions ,
Embezzlement ,
Extortion ,
Financial Institutions ,
FinCEN ,
Foreign Official ,
Misappropriation ,
Money Laundering ,
New Guidance ,
Offshore Funds ,
Public Corruption ,
Ransomware ,
Russia ,
Shell Corporations ,
Suspicious Activities ,
Suspicious Activity Reports (SARs)
The Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (the “Proposed Rule”) in late January seeking public comment on a proposed pilot program that would expand financial institutions’...more
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more
3/4/2022
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FinCEN ,
Guilty Pleas ,
Know Your Customers ,
Money Services Business ,
Office of Foreign Assets Control (OFAC)
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more
The innovative use of virtual currencies is hotter than ever, but so is a dark side of these instruments: their exploitation in ransomware schemes. This year, since January 2021, ransomware attacks have increased...more
12/30/2021
/ Cryptocurrency ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Management ,
Virtual Currency
The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more
8/20/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
FinTech ,
Popular ,
Suspicious Activity Reports (SARs) ,
Virtual Currency
Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more
10/9/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corruption ,
Financial Crimes ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Public Comment ,
Regulatory Agenda ,
Risk Assessment ,
White Collar Crimes
The Financial Crimes Enforcement Network (FinCEN) and federal banking regulators recently issued a Joint Statement intended to clarify the due diligence obligations of banks under the Bank Secrecy Act (BSA) regarding...more
9/17/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Customer Due Diligence (CDD) ,
FFIEC ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Joint Statements ,
Politically Exposed Person (PEPs) ,
Regulatory Requirements ,
Risk-Based Approaches
Earlier this month, senior officials of the global money laundering and terrorist financing watchdog—the Financial Action Task Force (FATF)—issued a paper identifying challenges, good practices, and policy responses to new...more
On March 4, 2020, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) assessed a civil monetary penalty of $450,000 against Michael LaFontaine, the former Chief Operational Risk Officer and...more
A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more
1/24/2020
/ Anti-Money Laundering ,
Bitcoin Mining ,
BSA/AML ,
CFTC ,
Corruption ,
Cryptocurrency ,
Currency Exchange ,
Digital Currency ,
Economic Sanctions ,
Financial Transactions ,
FinCEN ,
Geo-Blocking ,
Jurisdiction ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Oversight ,
Risk Management ,
Sanction Violations ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Strict Compliance ,
Strict Liability ,
Virtual Currency