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1 month ago | 
jdsupra.com | Siana Danch |Terence M. Grugan
Does it matter if a law is valid if the Government refuses to enforce it? For months, we have watched (and blogged on) courts grappling with the constitutionality and enforceability of the Corporate Transparency Act (“CTA”). While, as we have blogged most recently here, courts have produced mixed returns on the validity of the CTA, the Department of the Treasury (“Treasury”) has now significantly mooted those questions.
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2 months ago | 
jdsupra.com | J. Chesley Burruss |Siana Danch |Terence M. Grugan
Maksym Kaharlytskyi, UnsplashDevelopments concerning the enforceability and enforcement of the CTA came at a rapid clip last week. As things stand, the government may enforce the CTA pending a Texas court appeal in Smith v. U.S. Department of the Treasury. FinCEN indicated its intent to enforce the CTA but provided reporting companies with a revised deadline to submit the required reports. We have previously blogged about the litigation here and here.
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Dec 9, 2024 | 
jdsupra.com | Sterling Moose Busbee |J. Chesley Burruss |Siana Danch
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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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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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Nov 15, 2024 | 
jdsupra.com | Siana Danch
In the possible final stage of the Alpine Securities saga (as we blogged about here, here and here), Judge Clark Waddopous of the United States District Court for the District of Utah issued an opinion granting the Securities and Exchange Commission’s (“SEC”) motion to dismiss the amended complaint filed by plaintiff brokerage firm Scottsdale Capital Advisors (“SCA”).
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Oct 2, 2024 | 
jdsupra.com | J. Chesley Burruss |Siana Danch |Peter Hardy
Various industry groups have filed lawsuits in multiple federal districts challenging the constitutionality of the Corporate Transparency Act (“CTA”). The first such suit, filed in the Northern District of Alabama, resulted in a ruling by the District Court that the CTA was unconstitutional because Congress lacked the authority to enact the CTA. The government appealed this ruling, and the Eleventh Circuit heard oral argument on Friday, September 27.
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Aug 5, 2024 | 
jdsupra.com | Siana Danch |Peter Hardy |Kaley Schafer
Entitled “Notice to Customers: Beneficial Ownership Information Reference Guide,” the Guide is styled as a reference tool for business customers of banks who also are covered by the CTA. It is predominated by a chart, which we set forth at the end of this blog post, setting forth the differences in what information needs to be reported under the different reporting regimes.
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Jul 29, 2024 | 
jdsupra.com | Siana Danch
July 29, 2024
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In our first blog post in this series, we invited Don Fort, a former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division, to answer questions on utility of BSA filings from the perspective of law enforcement.
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Jul 17, 2024 | 
jdsupra.com | Siana Danch |Peter Hardy
Yesterday we were very pleased to welcome guest blogger, Don Fort, who is the Director of Investigations at Kostelanetz LLP, and the past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division. As Chief of IRS-CI from 2017 to 2020, Don led the sixth largest U.S. law enforcement agency, managing a budget of over $625 million and a worldwide staff of approximately 3,000, including 2,100 special agents in 21 IRS field offices and 11 foreign countries.
