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Dec 10, 2024 | 
mondaq.com | Matthew Bisanz |Gina M. Parlovecchio |Brad Resnikoff |Kelly F. Truesdale
On December 7, 2024, the US Financial Crimes Enforcement Network (FinCEN) confirmed that reporting companies—i.e., companies that would be required to report their beneficial ownership information to FinCEN under the Corporate Transparency Act (CTA) and its implementing regulations—are not required to file beneficial ownership reports for as long as the current, nationwide injunction of the CTA remains in effect.1 Further, FinCEN noted that reporting companies will have no liability for...
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Dec 4, 2024 | 
mondaq.com | Gina M. Parlovecchio |Justin Herring |Tamer A. Soliman |Adam Hickey
On November 26, 2024, the United States Court of Appeals for the
Fifth Circuit issued a landmark decision holding that the Treasury
Department's Office of Foreign Assets Control
("OFAC") exceeded its statutory authority by sanctioning
immutable smart contracts created byTornado Cash.
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Sep 25, 2024 | 
lexology.com | Jason N. Linder |Adam Hickey |J. Gregory Deis |Gina M. Parlovecchio |Juliet Gunev |Glen Kopp | +3 more
On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M.
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Sep 5, 2024 | 
mondaq.com | Brad Resnikoff |Gina M. Parlovecchio |Matthew Bisanz |Grace Kim
On August 28, 2024, the US Department of the Treasury's
Financial Crimes Enforcement Network (FinCEN) finalized a rule to require reporting of
certain US residential real estate transactions ("Final
Rule"). The Final Rule requires certain professionals involved
in real estate closings and settlements to report information to
FinCEN about non-financed transfers of residential real estate to
legal entities or trusts.
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Aug 7, 2024 | 
mondaq.com | Jason N. Linder |J. Gregory Deis |Gina M. Parlovecchio |Kelly Kramer
On August 1, 2024, the US Department of Justice ("DOJ"
or "Department") released highly anticipated details of its new
Corporate Whistleblower Awards Pilot Program ("Pilot
Program"), with Principal Deputy Assistant Attorney General
Nicole M.
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Jul 16, 2024 | 
mondaq.com | Gina M. Parlovecchio |Brad Resnikoff |Matthew Bisanz
On June 28, 2024, the US Department of Treasury's Financial
Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking ("June 2024
NPRM") to crystalize its long-held expectation that financial
institutions use risk assessments to design their anti-money
laundering and countering the financing of terrorism (AML/CFT)
programs.
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Apr 23, 2024 | 
mondaq.com | Jason N. Linder |Laurence Urgenson |Gina M. Parlovecchio |J. Gregory Deis
On April 15, 2024 the Criminal Division of the US Department of Justice ("DOJ") launched a pilot program to encourage voluntary self-disclosures by offering mandatory non-prosecution agreements ("NPAs") to individuals who report on certain types of criminal conduct involving corporations.1 From the date of the announcement, individuals who provide original and actionable information falling within certain categories of corporate crime, and who fully cooperate with authorities, and pay any...
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Mar 18, 2024 | 
mondaq.com | Jason N. Linder |J. Gregory Deis |Gina M. Parlovecchio |Kelly Kramer
On March 7, 2024, the Deputy Attorney General of the US
Department of Justice ("DOJ" or "Department")
announced a pilot program to encourage
whistleblowers to report evidence of high-priority white collar
crimes with the potential to recover financial rewards from any
funds forfeited as part of a resulting criminal enforcement
action.
As Deputy Attorney General Lisa O.
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Mar 1, 2024 | 
mondaq.com | Brad Resnikoff |Gina M. Parlovecchio |Matthew Bisanz |Grace Kim
On February 7, 2024, the US Department of the Treasury's
Financial Crimes Enforcement Network ("FinCEN") issued a
Notice of Proposed Rulemaking on certain US residential real estate
transactions ("2024 NPRM"). The 2024 NPRM would require
certain professionals involved in real estate closings and
settlements to report information to FinCEN about non-financed
transfers of residential real estate to legal entities or trusts.
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Feb 26, 2024 | 
lexblog.com | Brad Resnikoff |Gina M. Parlovecchio |Matthew Bisanz |Grace Kim |Grace Kim
On February 7, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking on certain US residential real estate transactions (“2024 NPRM”). The 2024 NPRM would require certain professionals involved in real estate closings and settlements to report information to FinCEN about non-financed transfers of residential real estate to legal entities or trusts.
