On March 1, 2024, a federal judge in the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (“CTA”) is unconstitutional. The CTA and its implementing regulations require that...more
3/13/2024
/ Alabama ,
Beneficial Owner ,
Civil Monetary Penalty ,
Corporate Transparency Act ,
Criminal Penalties ,
Deadlines ,
FinCEN ,
Fraud ,
Noncompliance ,
Penalties ,
Popular ,
Reporting Requirements ,
Transparency ,
Unconstitutional Condition
Companies need to be aware of filing requirements before taking foreign money -
On March 14, 2023, after a week of three bank failures that marked the largest such crisis since 2008, policymakers continued seeking private...more
3/15/2023
/ CFIUS ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Enforcement ,
Executive Orders ,
FDIC ,
Filing Requirements ,
Foreign Entities ,
Foreign Investment ,
Investment ,
National Security ,
Popular
New program may prohibit some U.S. investments in China -
On March 3, 2023, the U.S. Departments of the Treasury (“Treasury”) and Commerce (“Commerce”) delivered to Congress separate confidential reports that confirm the...more
3/8/2023
/ Biden Administration ,
CFIUS ,
China ,
Executive Orders ,
FIRRMA ,
Investment Adviser ,
Outbound Transactions ,
Popular ,
Semiconductors ,
U.S. Commerce Department ,
U.S. Treasury
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
10/26/2021
/ Audits ,
Cryptocurrency ,
Cybersecurity ,
FinCEN ,
Internal Controls ,
Money Laundering ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Assessment ,
Sanctions ,
Testing Requirements ,
Training ,
U.S. Treasury ,
Virtual Currency
FinCEN announces eight areas of focus and advises preparation for issuance of new regulations -
On June 30, 2021, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the first...more
7/8/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Corporate Transparency Act ,
Corruption ,
Cyber Crimes ,
Cybersecurity ,
Drug Trafficking ,
Financial Institutions ,
FinCEN ,
Fraud ,
Human Trafficking ,
New Regulations ,
Popular ,
Reporting Requirements ,
Significant Transnational Criminal Organization ,
Terrorism Funding ,
Virtual Currency ,
Whistleblowers
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers
Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks -
Amid...more
11/16/2020
/ Bitcoin ,
Cryptocurrency ,
Cyber Attacks ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Enforcement Guidance ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Securities and Exchange Commission (SEC)