Key takeaways FinCEN and Treasury announce that there will be no enforcement for failure to file beneficial ownership information reports with FinCEN by the March 21 deadline. Treasury announced intention to narrow the scope...more
As described in our previous client alert, on January 23, 2025, the Supreme Court of the United States stayed the nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas...more
A significant focus on tax compliance and follow-up enforcement actions may be on the horizon. We previously reported that the Internal Revenue Service (IRS) Cyber Crimes Unit had signaled its determination to increase...more
On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more
3/6/2020
/ Banks ,
Commodities ,
Economic Sanctions ,
Food Supply ,
Foreign Relations ,
General Licenses ,
Global Terrorism Sanctions Regulations (GTSR) ,
Humanitarian Assistance ,
Iran ,
Iran Sanctions ,
ITSR ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Reporting Requirements ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Switzerland ,
Trade Agreements
On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran.
Foreign governments and foreign financial institutions...more
11/8/2019
/ AML/CFT ,
Due Diligence ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Humanitarian Assistance ,
Iran ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Trump Administration
The Internal Revenue Service (IRS) has signaled for years that it would eventually bring enforcement actions against individuals who failed to report cryptocurrency gains. It appears that “eventually” is over and that those...more
8/24/2019
/ Capital Markets ,
Criminal Prosecution ,
Cryptocurrency ,
Currency Exchange ,
Enforcement Actions ,
Enforcement Programs ,
Failure to Report ,
Income Taxes ,
IRS ,
Reporting Requirements ,
Tax Fraud ,
Trading Platforms