CTA/BOI Held Unconstitutional
On March 1, 2024, a U.S. federal district court held in a 53 page opinion the “Corporate Transparency Act is unconstitutional because it...
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Elizabeth A. McMorrow
Jan 31
FinCEN Seeks Comments on BOI Access Rule
On January 29, 2024, the U.S. Financial Crimes Enforcement Network (FinCEN) announced it is seeking comments on two aspects of the...
Elizabeth A. McMorrow
Jan 30
FinCEN Updates CTA / BO Penalties
FinCEN issued a final rule on January 25, 2024, to reflect annual inflation adjustments to civil monetary penalties within its...
Elizabeth A. McMorrow
Dec 4, 2023
CTA Update: BOI 90-Day Registration
On November 29, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a final rule extending the deadline for certain reporting...
Elizabeth A. McMorrow
Nov 12, 2023
FinCEN Issued Final CTA Identifiers Rule
On November 7, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a final rule specifying the circumstances under which an...
Elizabeth A. McMorrow
Nov 10, 2023
FinCEN Issues New Key Term for SARs
On November 6, 2023, FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a joint notice to announce...
Elizabeth A. McMorrow
Oct 20, 2023
FinCEN Hamas SAR Alert & Crypto Mixer Reg
On October 20, 2023, FinCEN issued an alert to assist financial institutions (FIs) in identifying funding streams for Hamas. On October...
Elizabeth A. McMorrow
Sep 29, 2023
FinCEN Trio of CTA (BO) Updates
The U.S. Financial Crimes Enforcement Network (FinCEN) issued three notices this week regarding the U.S. Corporate Transparency Act...
Elizabeth A. McMorrow
Jul 13, 2023
New Director at FinCEN
The U.S. Financial Crimes Enforcement Network (FinCEN) announced Andrea Gacki as the new director on July 13, 2023. FinCEN is the part of...
Elizabeth A. McMorrow
Apr 28, 2023
FinCEN Discusses Updates to CTA / BO Registry
On April 27, 2023, the Acting Director of the Financial Crimes Enforcement Network (FinCEN) provided the U.S. House of Representatives...
Elizabeth A. McMorrow
Apr 26, 2023
Kingdom Trust Hit with $1.5 Million Penalty by FinCEN
On April 26, 2023, the U.S. Financial Crimes Enforcement Network (FinCEN) announced it assessed a $1.5 million civil money penalty on...
Elizabeth A. McMorrow
Jan 26, 2023
FinCEN Alert: U.S. Real Estate Investments by Sanctioned Russians
On January 25, 2023, FinCEN issued an alert regarding potential investments in the U.S. commercial real estate (CRE) sector by sanctioned...
Elizabeth A. McMorrow
Dec 27, 2022
FinCEN Published Proposed Beneficial Owner Information Access Rule
On December 16, 2022, the Financial Crimes Enforcement Network (FinCEN) published in the Federal Register the preliminary rules to...
Elizabeth A. McMorrow
Sep 29, 2022
FinCEN Announces Beneficial Ownership Reporting Deadlines
On September 29, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing a beneficial ownership...
Elizabeth A. McMorrow
Sep 11, 2022
FinCEN Looking Toward Digital IDs
On September 7, 2022, Jimmy Kirby, Acting Deputy Director of the Financial Crimes Enforcement Network (FinCEN) spoke at the 2022 Federal...
Elizabeth A. McMorrow
Jul 6, 2022
U.S. Financial Agencies Issue Joint Statement on Customer Risk
On July 6, 2022, five U.S. agencies responsible for various aspects of the U.S. financial industry issued a "Joint Statement on the...
Elizabeth A. McMorrow
May 26, 2022
FinCEN Holding Crypto to a High KYC Standard
On May 19, 2022, Alessio Evangelista, Associate Director of FinCEN’s Enforcement and Compliance Division spoke at the Chainalysis Links...
Elizabeth A. McMorrow
Apr 28, 2022
FinCEN Acting Director Provides CTA Update
On April 28, 2022, the Acting Director of the Financial Crimes Enforcement Network (FinCEN) provided the U.S. House of Representatives...
Elizabeth A. McMorrow
Jan 30, 2022
Are You Preparing for the New U.S. Beneficial Owner Registry?
The U.S. Corporate Transparency Act (“CTA”) was enacted on January 1, 2021. On December 8, 2021, the Financial Crimes Enforcement Network...
Elizabeth A. McMorrow
Sep 16, 2017
FBAR: October 16, 2017 Deadline for Ex-Pats and Other Employees to File
FBAR which stands for Foreign Bank and Financial Accounts Report is an annual report that provides the U.S. government with information...
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