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Dec 9, 2024 | 
jdsupra.com | Deborah Connor |Marc-Alain Galeazzi |Caroline Sir
As detailed in our client alert regarding the issuance of a preliminary injunction by the Eastern District Court of Texas against the Corporate Transparency Act (CTA), enforcement of the CTA and its reporting rules on beneficial ownership information (BOI) has been temporarily suspended. On December 5, 2024, the U.S. government filed an appeal to the United States Court of Appeals for the Fifth Circuit against this preliminary injunction.
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Dec 5, 2024 | 
jdsupra.com | Deborah Connor |Marc-Alain Galeazzi |Caroline Sir
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction against enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirement. As drafted, the CTA requires any entity that was formed or registered to do business in the United States prior to January 1, 2024, and does not fall into one of the 23 categories of exemptions, to report its BOI by January 1, 2025.
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Sep 26, 2024 | 
jdsupra.com | Deborah Connor |Marc-Alain Galeazzi |Joseph Gillman
Key Takeaways FinCEN has issued two new final rules to significantly expand regulation around certain investment adviser and residential real estate sectors to combat illicit finance in these areas. These highly anticipated regulations form part of a broader strategy to strengthen AML/CFT controls across new industries.
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Aug 7, 2024 | 
jdsupra.com | Patrick Byxbee |Carrie Cohen |Deborah Connor
On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue for individuals to disclose allegations of corporate wrongdoing directly to the government. Key Takeaways The Pilot Program seeks to incentivize individuals to report allegations of misconduct to DOJ’s Criminal Division.
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Aug 7, 2024 | 
lexology.com | Deborah Connor |James Koukios |Edward A. Imperatore |Carrie Cohen |Peter Skinner |Elizabeth Shaw | +1 more
On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue for individuals to disclose allegations of corporate wrongdoing directly to the government. Key TakeawaysThe Pilot Program seeks to incentivize individuals to report allegations of misconduct to DOJ’s Criminal Division.
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Jul 29, 2024 | 
jdsupra.com | Deborah Connor |Marc-Alain Galeazzi |Jordan Hare
Key Takeaways: The federal banking agencies proposed amending the anti-money laundering program requirements applicable to their supervised institutions for consistency with FinCEN anti‑money laundering program requirements. These requirements, if implemented, would codify certain longstanding supervisory expectations and guidance.
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Jul 8, 2024 | 
jdsupra.com | Deborah Connor |Marc-Alain Galeazzi |Kelley A. Howes
On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would require SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to implement and maintain a customer identification programs (CIP) to verify the identities of their customers.
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Jul 8, 2024 | 
lexology.com | Kelley A. Howes |Marc-Alain Galeazzi |Deborah Connor |Malka Levitin |Caroline Sir
On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would require SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to implement and maintain a customer identification programs (CIP) to verify the identities of their customers.
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Mar 19, 2024 | 
lexology.com | Carrie Cohen |Deborah Connor |Edward A. Imperatore |James Koukios |Peter Skinner
On March 7, 2024, during her keynote remarks at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new Department of Justice (DOJ) Criminal Division whistleblower pilot program (Pilot Program). The Pilot Program provides financial incentives for individuals to report allegations of corporate wrongdoing to DOJ.
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Mar 1, 2024 | 
jdsupra.com | Deborah Connor |Mark Edelstein |Thomas Fileti
On February 16, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking, which would require certain real estate professionals to report certain transaction information to FinCEN in connection with non-financed transfers of residential real estate to legal entities or trusts.
