News & Analysis as of September 23, 2024

FinCEN › Administrative Procedure Act

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

In Compliance: Holtzman Vogel's July 2024 Round-Up

Holtzman Vogel Baran Torchinsky & Josefiak on 8/2/2024

Holtzman Vogel attorneys wrote on the Supreme Court's landmark Loper Bright decision earlier this month. The Court overruled its 1984 decision in Chevron v. NRDC that introduced the so-called "Chevron deference" principle...more

Supreme Court Opens Door to More APA Challenges by Ruling that Right of Action Accrues When Regulation First Causes Injury

Ballard Spahr LLP on 7/5/2024

On July 1, 2024, the Supreme Court issued its opinion in Corner Post, Inc. v Board of Governors of the Federal Reserve System in which the Court determined when a Section 702 claim under the Administrative Procedure Act (APA)...more

Troutman Pepper Weekly Consumer Financial Services Newsletter - April 2024 # 5

Troutman Pepper on 4/30/2024

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

All Roads Lead to Roman: Alleged Tornado Cash Co-Founders Roman Storm Arrested and Roman Semenov Sanctioned, Days After Treasury...

Ballard Spahr LLP on 8/30/2023

Complex Civil and Criminal Cases Converge - On August 17, 2023, Judge Robert Pitman of the federal district court for the Western District of Texas issued an Order granting summary judgment for the U.S. Treasury Department...more

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

King & Spalding on 1/18/2021

After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

The SEC and SARs

Dorsey & Whitney LLP on 12/18/2020

The Commission periodically has filed enforcement actions against broker-dealers for failing to file SARs - suspicious activity reports - typically centered on a failure to file reports regarding microcap issuers. Those...more

FinCEN Announces New “Global Investigations Division” Focused on Foreign Money Laundering Threats

Ballard Spahr LLP on 8/29/2019

The Financial Crimes Enforcement Network (FinCEN) issued a press release yesterday, entitled “New FinCEN Division Focuses on Identifying Primary Foreign Money Laundering Threats.”...more

A “Death Sentence” for Financial Institutions: the D.C. Circuit Dismisses Andorran Bank Shareholders’ Challenge to FinCEN’s...

Ballard Spahr LLP on 5/30/2017

On May 23, the federal court of appeals for the District of Columbia Circuit rejected an appeal by the majority shareholders in Banca Privada d’Andorra S.A. (“BPA”) regarding claims that FinCEN violated the Administrative...more

Developing a Strategy to Fight FBAR Penalties

Carlton Fields on 5/4/2017

Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically. Originally published in The Tax Advisor....more

Financial Services Weekly News - September 2015

Goodwin on 9/3/2015

Regulatory Developments - California Department of Business Oversight Permits Money Transmitter to Treat Customer Funds in Designated Custodial Account as “Eligible Securities” - The California Department of...more

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FinCEN › Administrative Procedure Act

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