On December 3, 2024, the United States District Court for the Eastern District of Texas entered a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (“CTA”) and its implementing...more
12/9/2024
/ Corporate Transparency Act ,
Department of Justice (DOJ) ,
Enforcement ,
Financial Crimes ,
FinCEN ,
First Amendment ,
Fourth Amendment ,
Preliminary Injunctions ,
Reporting Requirements ,
Texas ,
Unconstitutional Condition
Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities -
SUMMARY -
On April 24, 2024, President Biden signed into law a foreign military...more
5/8/2024
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Sanction Violations ,
Self-Disclosure Requirements ,
Statute of Limitations ,
Trading with the Enemy Act ,
Voluntary Disclosure
Federal and state regulators have taken an increased interest in regulating cryptocurrencies, digital assets, and the larger blockchain ecosystem. This landscape is opaque and rapidly evolving, and many industry participants...more
9/25/2023
/ Anti-Money Laundering ,
Bitcoin ,
Bitcoin Mining ,
Blockchain ,
CFIUS ,
CFTC ,
Coinbase ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Ethereum ,
FinCEN ,
Fraud ,
Insider Trading ,
Ponzi Scheme ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Unregistered Securities
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers
Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks -
Amid...more
11/16/2020
/ Bitcoin ,
Cryptocurrency ,
Cyber Attacks ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Enforcement Guidance ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Securities and Exchange Commission (SEC)
In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more
11/5/2020
/ Bank Secrecy Act ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FATF ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Proposed Rules ,
Suspicious Activity Reports (SARs) ,
Travel Rule ,
Uniform Commercial Code (UCC) ,
Virtual Currency ,
Wire Transfers