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3 weeks ago | 
jdsupra.com | Peter Hardy |Eamonn K. Moran |Christopher Phillips
A recent opinion in Studco Building Systems US, LLC v. 1st Advantage Credit Union by the U.S. Court of Appeals for the Fourth Circuit addresses and limits the potential liability of beneficiary banks in business email compromise (BEC) schemes.
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1 month ago | 
jdsupra.com | Alan Granwell |Peter Hardy |Michael C. Titens
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 21, 2025, issued an interim final rule that recalibrates the Corporate Transparency Act (CTA).
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1 month ago | 
jdsupra.com | Gabriel Caballero Jr. |Andrés Fernández |Peter Hardy
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) to combat the illicit activities and money laundering of Mexico-based cartels, drug traffickers and other criminal actors along the Southwest U.S. border.
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1 month ago | 
jdsupra.com | Peter Hardy |Jessica Magee
On Feb. 18, 2025, in a case seeking declaratory and injunctive relief against the of the SEC, the U.S. Department of Justice (DOJ) filed a Notice of Change in Position indicating that the DOJ will no longer defend in litigation "the multiple layers of removal restrictions" set forth in 5 U.S.C. § 7521 for Administrative Law Judges (ALJs).
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Dec 10, 2024 | 
jdsupra.com | Peter Hardy
FinCEN has posted the following on its website in light of a recent litigation outcome regarding the Corporate Transparency Act (“CTA”) in the Eastern District of Texas. As we have blogged, and as the below notes, other federal district courts have reached opposite conclusions. Also, the Eleventh Circuit still needs to rule on related issues, which creates the possibility of confusion and conflicting results regarding the national application of the CTA.
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Dec 6, 2024 | 
jdsupra.com | Siana Danch |Peter Hardy |Kelly A. Lenahan-Pfahlert
In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado Cash, “an open-source, crypto-transactions software protocol that facilitates anonymous transactions by obfuscating the origins and destinations of digital asset transfers.” The opinion, which reversed the ruling of the District Court, is here.
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Dec 5, 2024 | 
ballardspahr.com | Wesley Robinson |Laura Giles |Terence M. Grugan |Peter Hardy
The U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction on December 3, 2024, in Texas Top Cop Shop, Inc., et al. v. Garland, et al. (No. 4:24-CV-0478).
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Nov 18, 2024 | 
jdsupra.com | Richard Andreano Jr. |Siana Danch |Peter Hardy
As we previously blogged, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.
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Oct 28, 2024 | 
jdsupra.com | Peter Hardy
The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”). The Consent Order describes Lake Elsinore, located in California, as a “medium-sized card club” with 22 tables offering card games such as poker.
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Oct 18, 2024 | 
jdsupra.com | Peter Hardy |Kaley Schafer
The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of proposed rulemaking (“NPRM”) to modernize financial institutions’ anti-money laundering and countering terrorist financing (“AML/CFT”) programs (“Comment”).
