OFAC’s recent “Guidance on Sham Transactions and Sanctions Evasion” suggests heightened due diligence obligations and erodes the “bright line” distinction between ownership and ...
FinCEN and OFAC have taken steps to implement the AML/CFT and sanctions compliance obligations under the GENIUS Act, the most notable of which include compliance requirements applicable t...
FinCEN and the federal banking agencies released proposed AML/CFT program rules that largely reorganize the compliance requirements that were initially proposed in 2024 and introduce a ne...
This visual memorandum provides a summary and overview of the Department of the Treasury’s proposed rules that would update requirements for anti-money laundering and countering the fin...
The SEC announced its 2025 enforcement results while outlining shifts in its enforcement priorities to focus on fraud, market manipulation and individual accountability.
In his first public remarks since becoming CFTC Director of Enforcement, David Miller outlined his enforcement priorities, which are focused on serious cases implicating fraud, market man...
FinCEN’s proposed rule would offer significant financial incentives to individuals who report corporate violations of anti-money laundering, sanctions and national security laws across ...
FinCEN announced that it will not enforce reporting requirements under its residential real estate rule following the U.S. District Court for the Eastern District of Texas’s decision to...
On March 10, 2026, the Department of Justice announced its first ever Department-wide corporate enforcement policy for all criminal cases. Under the new policy, companies that self-repor...
On February 24, 2026, the U.S. Attorney’s Office for the Southern District of New York announced a new policy to incentivize companies to self-report financial crimes. Companies could b...
