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The Real (Estate) Deal: FinCEN’s New Reporting Requirements for Property Transfers

In response to illicit finance risks identified in the U.S. residential real estate sector, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced the issuance of its long-anticipated...more

Don’t pop the champagne; the CTA isn’t dead ... yet.

On Friday, March 1, 2024, U.S. District Court Judge Liles Burke ruled that the Corporate Transparency Act (CTA) is unconstitutional because Congress exceeded its powers to regulate interstate commerce, oversee foreign affairs...more

Data Protection Demands Complicate CTA Compliance

On Jan. 1, the Corporate Transparency Act (CTA) went into effect, premised on the belief that illicit actors use corporate structures like shell companies and fronts to hide their identities and launder criminal proceeds...more

U.S. Treasury Issues Notice of Anti-Money Laundering Regulations for Residential Real Estate Transfers

On Feb. 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM)1 in response to illicit finance risks identified in the U.S. residential real estate...more

Investment Advisers Beware: The BSA is Coming (Maybe)

The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a notice of proposed rulemaking (NPRM) that would subject registered investment advisers (RIAs) and exempt reporting...more

U.S. Treasury Renews Push to Make Investment Advisers Subject to the BSA

The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more

OFAC Designates Tornado Cash as a Sanctioned Entity as Federal Government Continues to Increase Regulation of Decentralized...

On Aug. 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned cryptocurrency mixer Tornado Cash for allegedly helping launder more than $7 billion worth of cryptocurrency over three years.1...more

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