Reporting companies should take note of a recent clarification by the Financial Crimes Enforcement Network ("FinCEN") that the Beneficial Ownership Information ("BOI") Rule requires reporting companies that exist on or after...more
On March 1, 2024, New York State Governor Kathy Hochul signed into law a revised version of New York State's LLC Transparency Act, which is modeled on FinCEN's Beneficial Ownership Information Rule. Other states are...more
The Financial Crimes Enforcement Network ("FinCEN") has issued a final rule ("Final Rule") extending the initial reporting deadline for new entities required to file beneficial ownership information ("BOI") with FinCEN to 90...more
An estimated 32.6 million domestic and foreign companies will soon be required to report information about their beneficial owners to the U.S. Treasury. This White Paper describes the new requirements and the steps companies...more
In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more
8/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Agents Registration Act (FARA) ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
In Short -
The Situation: Terrorists may be increasingly turning to cryptocurrencies to evade sanctions and finance terrorist acts, as recent prosecutions and reports suggest. Under the Antiterrorism Act ("ATA"), as...more
In 2022, anti-money laundering ("AML") and sanctions controls were at the center of regulatory and enforcement activities in the United States and abroad. Globally, governments have continued to recognize the impact of AML...more