The beneficial ownership information (“BOI”) registry under the Corporate Transparency Act (“CTA”) is now up and running at the Financial Crimes Enforcement Network (“FinCEN”). This post will follow up on a previous blog regarding the recently-published CTA BOI access regulations
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SDNY Grants Ex Parte Applicants the Ability to Subpoena Deutsche Bank Entities as Part of Ongoing AML-Related Litigation Against Danske Bank
On December 14, 2023, the United States District Court for the Southern District of New York (the “Court”) granted an unusual ex parte application to serve third-party discovery subpoenas on U.S.-based Deutsche Bank entities. The subpoenas seek evidence to assist…
Money Laundering Watch: 2023 Year in Review
Farewell to 2023, and welcome 2024. As we do every year, let’s look back.
We highlight 10 of our most-read blog posts from 2023, which address many of the key issues we’ve examined during the past year: criminal money laundering…
FinCEN Issues Final CTA BOI Access Rules, Heralded by YouTube Video
This morning, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial ownership information (“BOI”) reported to FinCEN. These regulations could hardly have arrived any later than…
OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs
In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of the federal banking system,…
Hamas, Terrorist Financing, and Cryptocurrency
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 cryptocurrency. This heightened focus is…
FinCEN Extends CTA Reporting Deadline for New Companies from 30 to 90 Days
The Financial Crimes Enforcement Network (“FinCEN”) has extended the deadline for reporting beneficial ownership information (“BOI”) under the Corporate Transparency Act (“CTA”) for reporting companies formed in 2024. Specifically, FinCEN has extended the filing deadline from 30 to 90 days from…
FinCEN Issues Alert on COVID-19 Employee Retention Tax Credit Fraud
On November 22, 2023, the Financial Crimes Enforcement Network (“FinCEN”), in close coordination with the Internal Revenue Service (“IRS”) Criminal Investigation (“CI”), issued an alert (“Alert”) regarding the COVID-19 Employee Retention Credit (“ERC”). The Alert echoes the FinCEN’s previous Notice…
Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Multiple Billions – While its Founder, Owner and Former CEO Zhao Pleads Guilty to Single AML Crime
A Huge Monetary Penalty for Sprawling Allegations – But Will Zhao Receive a Prison Sentence?
As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S.…
FinCEN Expands CTA FAQs
On November 16, the Financial Crimes Enforcement Network (“FinCEN”) issued – again –expanded FAQs pertaining to beneficial ownership information (“BOI”) reportable under the Corporate Transparency Act (“CTA”). These expanded FAQs enlarge upon the previously expanded FAQs set forth by FinCEN…