-
2 months ago | 
jdsupra.com | Erin Carrigan |Marc-Alain Galeazzi |Malka Levitin
On January 23, 2025, the U.S. Supreme Court granted the federal government’s motion to stay the nationwide injunction blocking the Corporate Transparency Act’s (CTA) enforcement, issued by the federal district court of the Eastern District of Texas in Texas Top Cop Shop, Inc. v. McHenry (formerly Texas Top Cop Shop v. Garland et al. (E.D. Tex., No. 4:24-cv-00478)).
-
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.
-
Dec 5, 2024 | 
jdsupra.com | Marc-Alain Galeazzi |Malka Levitin
Key Takeaways Generative artificial intelligence tools are enabling criminals to falsify identification documents in order to open accounts at financial institutions. The Financial Crimes Enforcement Network has issued a press release and alert to advise financial institutions on how to detect synthetic media. The alert reflects a broader governmental trend to combat fraud and cybercrime.
-
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.
-
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.
-
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.
-
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.
-
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.
-
Feb 27, 2024 | 
jdsupra.com | Deborah Connor |Marc-Alain Galeazzi |Kelley A. Howes
In July 2020, a sensitive Federal Bureau of Investigation (FBI) document was leaked to the public. The document outlined the FBI’s suspicions that the private investment funds industry was providing choice money laundering vehicles for bad actors. In the report, the FBI called for regulatory action in response. Four years later, the Financial Crimes Enforcement Network (FinCEN) has answered the call, with a February 15th Notice of Proposed Rulemaking (NPRM).
-
Feb 8, 2024 | 
jdsupra.com | Deborah Connor |Thomas Fileti |Marc-Alain Galeazzi
This client alert is an update to an earlier alert issued on December 8, 2022. In a final rule implementing the Corporate Transparency Act (the “Final Rule”), the Financial Crimes Enforcement Network (“FinCEN”) requires entities that own and operate U.S. real estate to report their “Beneficial Owners”—the natural persons that ultimately own or control such entities—to FinCEN.
