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The Second Trump Administration’s First 100 days

The first 100 days of the second Trump Administration have been marked by a flurry of Executive Orders (EOs) and policy memoranda intended to advance President Donald Trump’s “America First” agenda. In the process, these...more

Cartels, China, and Fentanyl-Related Illicit Finance

FinCEN report reveals threat patterns and trends for financial institutions to monitor - The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury (Treasury) published a Financial Trend Analysis...more

AG Bondi Releases Memos on Cartels and Joint Task Force October 7: Implications for Industry

The US Department of Justice (DOJ)’s Attorney General, Pam Bondi, recently released over a dozen memoranda on a variety of policies – ranging from plea agreements and sentencing criteria, to the DOJ’s amplified focus on...more

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Fifth Circuit Vacates Stay of Corporate Transparency Act Injunction, Again Putting Deadlines on Hold

On December 26, 2024, the US Court of Appeals for the Fifth Circuit vacated the stay entered by a motions panel days earlier, which would have allowed the government to enforce the Corporate Transparency Act (CTA) while it...more

Fifth Circuit Stays Injunction Halting Corporate Transparency Act’s Enforcement; Treasury Updates Deadline to January 13, 2025 for...

On December 23, 2024, the US Court of Appeals for the Fifth Circuit issued an order granting the government's emergency motion for a stay pending appeal of the preliminary injunction against the Corporate Transparency Act...more

Reporting Companies Should Remain Flexible Given Uncertain Future of the Corporate Transparency Act after Texas Court Grants...

Congress passed the Corporate Transparency Act (CTA) as an anti-money laundering initiative in 2021 designed to combat the use of anonymous “shell companies” to facilitate money laundering, terrorist financing, and threaten...more

‘Tis the season and past time for a ho-ho-hum approach to Corporate Transparency Act reporting deadline

Time is running out for Corporate Transparency Act (CTA) compliance. The law, which became effective on January 1, 2024, requires certain entities – or “reporting companies” – to disclose information about their beneficial...more

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more

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