On March 2, 2025, the U.S. Treasury Department announced that it would not enforce penalties or fines associated with beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA)...more
On February 18, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are...more
On December 23, 2024, the United States Court of Appeals for the Fifth Circuit reinstated the immediate enforceability of the Corporate Transparency Act (CTA). In the case Texas Top Cop Shop, Inc. v. Garland, a three-judge...more
On December 3, 2024, in Texas Top Cop Shop, Inc., et al. v. Garland, et al. (Case No. 4:24-cv-478-ALM), the U.S. District Court for the Eastern District of Texas issued a preliminary nationwide injunction against the...more
As discussed in our previous client advisory, earlier this month, the U.S. District Court for the Northern District of Alabama entered a final declaratory judgment concluding that the Corporate Transparency Act (“CTA” or the...more
On January 1, 2024, the new beneficial ownership information reporting requirements (BOIR) went into effect under the Corporate Transparency Act (CTA). Among other things, beneficial ownership reporting is intended to make it...more
The Corporate Transparency Act (CTA), which becomes effective on January 1, 2024, creates novel obligations for millions of entities to report beneficial ownership information (BOI) and certain other information to the U.S....more
Under the Corporate Transparency Act (CTA), which we have previously written about, reporting companies are required to report to the Financial Crimes Enforcement Network (FinCEN) certain identifying information about...more
The US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published its Small Entity Compliance Guide (the “Guide”) for the Corporate Transparency Act (the “CTA”) on September 18, 2023. The Guide...more
On January 1, 2024, the Corporate Transparency Act (the “CTA”) comes into effect for reporting companies formed after that date, with reporting for existing companies taking effect a year later. With approximately six months...more
On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions to be vigilant against attempts to evade recent U.S. sanctions imposed on Russia’s following that country’s...more
The U.S. Department of Justice (“DOJ”) has focused on cryptocurrency in the last six months, while consumer interest hits all-time highs. The cryptocurrency market is not unlike the cannabis market from several years...more
3/24/2021
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Bank Secrecy Act ,
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Cryptocurrency ,
Department of Justice (DOJ) ,
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Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
Compliance Failures - On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a consent order assessing a $450,000 civil money penalty against Michael LaFontaine, former Chief...more
On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules which codify customer due diligence requirements for financial institutions (the “CDD Rule”)[1] under the Bank Secrecy Act (the “BSA”). ...more
FinCEN Exchange to encourage information sharing
In December 2017, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced the creation of a platform to facilitate information sharing on a voluntary...more
On May 11, 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) Final Rule codifying new and existing customer due diligence (“CDD”) requirements under the Bank Secrecy Act (“BSA”) was...more