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FTC Issues "Debanking" Warning Letters to Payment Industry

Federal Trade Commission (FTC) Chairman Andrew Ferguson on March 26, 2026, issued warning letters to four major nonbank financial infrastructure platforms and payment providers, cautioning that denying consumers access to...more

FinCEN Imposes Record Penalty on Broker-Dealer: Compliance Lessons Going Forward

The Financial Crimes Enforcement Network (FinCEN) entered into a consent order on March 6, 2026, imposing an $80 million civil money penalty against a global broker-dealer (Broker-Dealer)  – the largest Bank Secrecy Act (BSA)...more

Recent FinCEN Actions Signal Trump Administration's Focus on Escalating AML Enforcement

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) recently announced a sweeping enforcement operation targeting money services businesses (MSBs) operating along the Southwest U.S. border....more

Eleventh Circuit Upholds Constitutionality of Corporate Transparency Act

In National Small Business United v. U.S. Department of the Treasury, a panel of the U.S. Court of Appeals for the Eleventh Circuit reversed the ruling of the U.S. District Court for the Northern District of Alabama, which...more

IRS and ICE Memorandum of Understanding Will Drive Tax Payroll Audits and Investigations

In a lawsuit filed by not-for-profit corporations serving Latino immigrants against the U.S. Secretary of the Treasury and IRS, court filings have revealed that the IRS and U.S. Department of Homeland Security (DHS), acting...more

Fourth Circuit Limits Beneficiary Bank Liability in BEC Schemes, Requires Actual Knowledge

Business email compromise (BEC) fraud, driven by technology and increasing sophistication by criminal organizations, has become a major issue for both consumers and financial institutions. According to a September 2024...more

Corporate Transparency Act Interim Final Rule Issued

In the latest development of the ongoing Corporate Transparency Act (CTA) saga, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 21, 2025, issued an interim final rule that...more

FinCEN Geographic Targeting Order Imposes Additional Recordkeeping and Reporting Requirements

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more

DOJ Forsakes Defending the ALJ Process Against Article II Challenges

On Feb. 18, 2025, in a case seeking declaratory and injunctive relief against the SEC, the U.S. Department of Justice (DOJ) filed a Notice of Change in Position indicating that the DOJ will no longer defend in litigation "the...more

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