On December 26, 2024, the US Court of Appeals for the Fifth Circuit issued an order in Texas Top Cop Shop, Inc. et al. v. Garland et al., that effectively pauses beneficial ownership information (BOI) reporting requirements...more
On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule that expressly includes certain investment advisers in the definition of a “financial institution”...more
In late June 2024, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule to modernize the anti-money laundering (AML) and countering the financing of terrorism (CFT) program...more
On May 13, 2024, the US Securities and Exchange Commission (SEC) and the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly issued a notice of proposed rulemaking that would require investment...more
The US Department of the Treasury has released an Illicit Finance Risk Assessment of Decentralized Finance, which indicates that the Treasury Department sees significant risks associated with decentralized finance (DeFi)...more
Background On Friday, March 10, 2023, Silicon Valley Bank (SVB) was closed by the California Department of Financial Protection and Innovation (DFPI). The Federal Deposit Insurance Corporation (FDIC) was named Receiver and...more
The Federal Reserve Board recently released a discussion paper and is seeking public comments on the potential benefits and risks, and related policy considerations, of introducing a central bank digital currency (CBDC) in...more
On November 18, 2021, three US agencies – the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and the Federal Deposit Insurance Corporation (FDIC) – issued a joint rule concerning...more
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued Sanctions Compliance Guidance for the Virtual Currency Industry. The guidance published on October 15, 2021, outlines OFAC’s...more