On May 13, the US Securities and Exchange Commission (SEC) and the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) jointly released a notice of proposed rulemaking (NPRM) which, if...more
In March 2024, the Northern District of Alabama held that Congress exceeded its Constitutional authority by enacting the Corporate Transparency Act (“CTA”). The CTA requires variety corporate entities—everything from LLCs to...more
Let me start by translating that headline to English. On February 15, 2024, the Financial Crimes Enforcement Network (FinCEN) division of the Department of Treasury issued a rule proposal that would require investment...more
The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a notice of proposed rulemaking (NPRM) that would subject registered investment advisers (RIAs) and exempt reporting...more
The Corporate Transparency Act was passed by Congress with bipartisan support in 2021 and went into effect on January 1, 2024. Broadly speaking, the law requires private companies to file a report with the Department of...more
On the one hand, the year ended where it began. The legislation on stabelecoins and market structure that would provide a regulatory framework for digital assets has still not been enacted into law. And Securities and...more
Beginning January 1, 2024, most small businesses in the United States will have to report information about the people who own and control the business to the federal government. This new reporting rule was established by...more
A new regulation under the federal Corporate Transparency Act (CTA) that, for the first time, will require disclosure of information about all U.S. formed corporations, limited liability companies, and limited partnerships...more
The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more
October 27, 2023- The U.S. Department of the Treasury's Office of Foreign Assets Control imposed a second round of sanctions on key Hamas-linked officials and financial networks....more
Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more
On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its first “Gap Rule” enforcement action in a Consent Order with Bancrédito International Bank and Trust...more
On April 6, 2023, the US Department of the Treasury released a report analyzing the risks of decentralized finance (DeFi) and potential vulnerabilities in the United States' anti-money laundering (AML) and countering the...more
The Corporate Transparency Act is now poised to take effect on January 1, 2024 (the “Effective Date”), and will immediately impose sweeping new disclosure duties when new entities are formed. During 2024, the other CTA shoe...more
Domestic terrorism is not a new threat in America, but in recent years we have seen a significant and horrific increase in violent attacks and activities carried out by individuals and groups motivated by a range of radical...more
This coming Saturday is the 20th anniversary of the attacks upon America on September 11, 2001. Like most Americans, this was the seminal event in the history of our country. I have been thinking a lot about that date and the...more
The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/CFT threats. ...more
First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more
On 2/6/2020, the U.S. Department of the Treasury issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy). The purpose of the 2020 Strategy is to...more
The President on September 10, 2019, authorized the Treasury Secretary to impose sanctions on non-U.S. financial institutions that have knowingly conducted or facilitated a “significant” transaction with anyone sanctioned by...more
As it targets terrorist groups and their finances, the U.S. Government announces potent secondary sanctions that can impede correspondent banking relationships of non-U.S. banks. A new U.S. Executive Order updates the...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more
On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently...more