Developments concerning the enforceability and enforcement of the CTA came at a rapid clip last week. As things stand, the government may enforce the CTA pending a Texas court appeal in Smith v. U.S. Department of the...more
The Fifth Circuit has granted the government’s request to stay temporarily the order and injunction issued by the United States District Court for the Eastern District of Texas, which had issued a nationwide stay prohibiting...more
12/24/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
Various industry groups have filed lawsuits in multiple federal districts challenging the constitutionality of the Corporate Transparency Act (“CTA”). The first such suit, filed in the Northern District of Alabama, resulted...more
The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of New York, denying a...more
11/17/2023
/ Administrative Procedure Act ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Declaratory Judgments ,
Department of Justice (DOJ) ,
Due Process ,
Enforcement Actions ,
Federal Reserve ,
Financial Crimes ,
Financial Institutions ,
Money Laundering ,
Preliminary Injunctions ,
Puerto Rico ,
Suspicious Activity Reports (SARs)