On March 1, 2024, the United States District Court for the Northern District of Alabama found that the Corporate Transparency Act (CTA) is unconstitutional because it exceeds Congress’ legislative power. The 53-page opinion...more
The Financial Crimes Enforcement Network (FinCEN) has proposed extending the deadline for certain companies to comply with the Corporate Transparency Act (CTA) and report their beneficial ownership information (BOI) from 30...more
Certain companies will soon have to give the Financial Crimes Enforcement Network (FinCEN) a look behind the corporate veil. In December 2021, FinCEN issued a Notice of Proposed Rulemaking (NPRM) seeking comment on one...more
The US continues to ramp up sanctions pressure on Russia, now emphasizing Russian efforts to evade US export controls and obligations of financial institutions to police Russian efforts at sanctions and export controls...more
7/6/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
FinCEN ,
Foreign Relations ,
General Licenses ,
Military Conflict ,
Oil & Gas ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
Our quarterly Financial Crime Horizon Scanner for the US summarizes key financial crime related legal and regulatory changes expected over the next 2 years and provides electronic links to key resources.
We hope that you...more
5/2/2022
/ Belarus ,
Beneficial Owner ,
Climate Change ,
Department of Justice (DOJ) ,
Digital Assets ,
Economic Sanctions ,
Export Controls ,
Financial Crimes ,
FinCEN ,
Infrastructure Investment and Jobs Act (IIJA) ,
Non-Fungible Tokens (NFTs) ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Russia ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Uyghur Forced Labor Prevention Act (UFLPA)
On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more
3/21/2022
/ Anti-Money Laundering ,
Compliance ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Russia ,
Terrorist Financing Regulations ,
Virtual Currency
On February 4, 2022, the US Department of the Treasury (the Treasury) released the “Study of the Facilitation of Money Laundering and Terror Finance through the Trade in Works of Art” (the Report). The Report examines the...more
2/18/2022
/ Anti-Money Laundering ,
Art Dealers ,
Bank Secrecy Act ,
Blockchain ,
BSA/AML ,
Compliance ,
Financial Institutions ,
FinCEN ,
Fine Art ,
Non-Fungible Tokens (NFTs) ,
Popular ,
U.S. Treasury
The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more
On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) provided an update on implementation of the Anti-Money Laundering Act of 2020 (AML Act) and issued the first government-wide priorities for anti-money...more
7/9/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Biden Administration ,
Corporate Transparency Act ,
Cyber Crimes ,
Cybersecurity ,
Enforcement Priorities ,
Financial Institutions ,
FinCEN ,
Suspicious Activity Reports (SARs)
The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has published an Advance Notice of Proposed Rulemaking (the Proposed Rule) seeking input from the public on the implementation of a reporting...more
On January 1, 2021, the US Senate voted to override President Donald Trump’s veto of H.R. 6395, the National Defense Authorization Act for Fiscal Year 2021 (NDAA). As part of the NDAA, the Anti-Money Laundering Act of 2020...more
1/8/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Congressional Override ,
Financial Institutions ,
FinCEN ,
Foreign Banks ,
NDAA ,
Patriot Act ,
Presidential Veto ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
Transparency ,
Whistleblower Protection Policies
On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to establish new requirements for convertible virtual currency (CVC) and legal tender digital asset (LTDA)...more
On July 30, 2020, the Financial Crimes Enforcement Network (FinCEN) released an advisory that signals its focus on cybercrime arising from vulnerabilities potentially created by the COVID-19 pandemic. The “Advisory on...more
The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more
1/20/2020
/ Annual Reports ,
Anti-Money Laundering ,
Banks ,
BSA/AML ,
Chief Compliance Officers ,
Compliance ,
CSBS ,
Examination Priorities ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Interpretive Opinions ,
Joint Statements ,
OCC ,
Risk Assessment ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
Technology ,
Terrorism Funding
Last week, the Financial Crimes Enforcement Network (FinCEN) and its regulatory partners issued a joint statement in an effort to increase transparency around risk-focused Bank Secrecy Act/anti-money laundering supervision....more