On September 2, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), the Board of Governors of the Federal Reserve System (“Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), and the Office of the Comptroller of the Currency (“OCC”) issued a joint statement on a question… Continue Reading
The long saga of the Corporate Transparency Act’s (“CTA”) beneficial ownership reporting requirements has reached its final chapter — at least for domestic businesses. On August 11, 2026, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule permanently exempting all U.S. companies and U.S. persons from reporting beneficial ownership information (“BOI”), which was the… Continue Reading
On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) that would formalize and, in certain respects, update the requirements for financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs under the Bank Secrecy Act (“BSA”). While FinCEN has characterized… Continue Reading
On March 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) submitted a Notice of Proposed Rulemaking (“NPRM”) for publication in the Federal Register that would, for the first time, establish a comprehensive framework for paying monetary awards to individuals who report violations of the Bank Secrecy Act (“BSA”), U.S. sanctions… Continue Reading
On March 6, 2026, the SEC and FinCEN announced parallel enforcement actions against a New York-based registered broker-dealer for systemic anti-money laundering (“AML”) failures, imposing combined penalties of $80 million – the largest ever imposed against a broker-dealer for BSA violations. FinCEN’s $80 million headline penalty includes credits of $20 million each to the SEC… Continue Reading
Executive Summary: On June 9, Deputy Attorney General Todd Blanche issued a memorandum to the Department of Justice’s Criminal Division, outlining the Department’s focus for pending and future FCPA actions. A day later, Matthew Galeotti, the Head of the Criminal Division, offered more insight into how this administration will approach FCPA investigations and enforcement actions. … Continue Reading
On June 16, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (USAO-SDTX) announced their decision to decline prosecution of White Deer Management LLC (White Deer), a private equity firm that voluntarily disclosed export control and sanctions violations committed by its newly acquired… Continue Reading
In a significant move signaling Europe’s growing autonomy in global anti-corruption enforcement, prosecutors from the United Kingdom, France, and Switzerland have formed a new cross-border alliance: the International Anti-Corruption Prosecutorial Taskforce. Announced on March 20, 2025 by the U.K.’s Serious Fraud Office (SFO), the taskforce is designed to deepen cooperation among these three countries on… Continue Reading
The guidance U.S. companies have been waiting for after years of ups and downs is finally here. In line with our last update, on March 21, 2025, FinCEN issued an interim final rule exempting U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information under the Corporate Transparency Act (CTA)… Continue Reading
After the Financial Crimes Enforcement Network (FinCEN) stated that it would hold off on taking enforcement actions against Reporting Companies for failure to comply with the March 21, 2025, deadline under the Corporate Transparency Act (CTA), the U.S. Department of the Treasury announced its own intention to limit CTA enforcement to foreign companies.… Continue Reading
The Financial Crimes Enforcement Network (FinCEN) published new guidance on Feb. 27, 2025, putting its plan to begin enforcing the Corporate Transparency Act (CTA) on hold. After the Feb. 17 order by the U.S. District Court for the Eastern District of Texas in Smith v. United States Department of Treasury made the CTA once again… Continue Reading
In our last update, we reported that despite the Supreme Court staying the nationwide injunction against FinCEN’s enforcement of the CTA in one Texas case, a nationwide stay of the Reporting Rule granted by a federal judge in the Eastern District in Smith v. United States Department of Treasury (6:24-cv-00336) remained in effect. … Continue Reading
Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security”), companies with cross-border business operations have likely faced questions from both internal and external stakeholders… Continue Reading
Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA). The Order directs Attorney General (AG) Pam Bondi to review guidelines and policies governing FCPA investigations and enforcement actions in the next 180 days,… Continue Reading
Another flurry of court activity has further muddied the Corporate Transparency Act (CTA) waters, leaving additional uncertainty about its enforceability. You may recall that on December 26, 2024, the Fifth Circuit vacated its own order granting the Government’s motion to stay the district court’s preliminary injunction, leaving FinCEN unable to enforce the CTA and lifting any filing… Continue Reading
A flurry of activity in the Fifth Circuit this holiday season left clients asking the same questions about the Corporate Transparency Act (CTA): “Do we report Beneficial Ownership Information?” “If so, when is the deadline?” “Will this Act survive judicial review?” You may recall that on December 26, 2024, the Fifth Circuit vacated the “part… Continue Reading
In recent years, the Biden Administration has been vocal that combatting foreign public corruption is a key pillar of its national security efforts.[1] Consistent with those policy goals, on December 22, 2023, Congress passed the Foreign Extortion Prevention Act (FEPA), a long-awaited complement to the Foreign Corrupt Practices Act (FCPA). Where the FCPA targets those… Continue Reading
Last week, the U.S. Department of Justice (DOJ) announced that Sweden-based multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson) will plead guilty to breaching the Foreign Corrupt Practices Act (FCPA) and has agreed to pay over $206 million in related penalties following its alleged breach of a 2019 Deferred Prosecution Agreement (DPA) with the Department.… Continue Reading
Key developments in U.S. cross-border enforcement were driven by the year’s most newsworthy developments, from Russia’s invasion of Ukraine and the battery of sanctions that swiftly followed, to the collapse of the cryptocurrency market. For details, download this inaugural review, which focuses on anti-money laundering, as this issue continued its rise up the enforcement and… Continue Reading
On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). The São Paulo-based company, whose shares are traded on the New York Stock Exchange, consented to a cease-and-desist order with the SEC… Continue Reading
On April 20, 2022, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) separately announced that Stericycle Inc. (Stericycle), an international waste management company headquartered in Lake Forest, Illinois, has agreed to pay more than $84 million to resolve parallel investigations by authorities in the United States and Brazil. The investigation is… Continue Reading
Without fanfare, DOJ recently published a “declination and disgorgement letter,” the first FCPA declination published by the Department since August 2020.… Continue Reading
RELATED UPDATES: U.S. Department of Justice and Partners Increasing Enforcement of Sanctions and Export Controls (March 6, 2023) New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022) Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022) FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions… Continue Reading
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