Michael G. Sanders

U.S. DOJ Seeks to Pause or Narrow Injunction Blocking CTA; District Court Orders Expedited Briefing

DOJ Appeals CTA Injunction; FinCEN Suspends Filing Requirement

Federal District Court Enjoins Enforcement of U.S. Corporate Transparency Act

FinCEN Imposes AML Program and SAR Filing Requirements on Investment Advisers

Another Step Towards Federal AML Obligations for Investment Advisers

OFAC Allows Venezuelan Oil and Gas Authorization to Expire and Extends Prohibitions to Execution on PdVSA 2020 Bond Collateral

FinCEN Tries Again . . . to Impose AML Requirements on Investment Advisers

Countdown to Implementation of US Beneficial Ownership Reporting

OFAC Eases Venezuela Sanctions Lifts Secondary Market Trading Ban on US Persons

FinCEN Proposes Rule Regarding Access to Beneficial Ownership Information under the Corporate Transparency Act

Preparing for Digital Asset Developments in 2023

OFAC and FinCEN Announce Joint Enforcement Action Against U.S.-Based Digital Asset Exchange

FINCEN’s Corporate Beneficial Ownership Reporting Rule: Significance for Investment Advisers

U.S. Treasury Adopts Final Corporate Beneficial Ownership Reporting Rule

FinCEN Proposes Corporate Beneficial Ownership Reporting Rule

FinCEN Requests Input on Potential AML Requirements for Real Estate Transactions

OFAC Ramps up Targeting of Ransomware-linked Actors and FinCEN Updates Ransomware Advisory

OFAC Issues Sanctions Guidance to Virtual Currency Industry

Cryptocurrency and Other New Forms of Financial Technology: Potential Terrorist Financing Concerns and Liability

OFAC Settles With Digital Currency Payment Processor for Sanctions Violations

OCC Affirms Authority of National Banks to Engage in Additional Cryptocurrency-Related Activities, Including Issuing Stablecoins

FDIC Finalizes Rule for Supervision of ILC Parents

Congress Overhauls AML Framework, Mandating Disclosure of Beneficial Ownership Information

Online Financial Service Companies: The Anti-Terrorism Act’s Next Frontier

FDIC Approves Two New ILCs and Proposes Supervision of ILC Parents

District Court Decision Incorrectly Holds that OFAC Sanctions Bar PdVSA

United States Designates the Government of Venezuela for Blocking Sanctions

Cuba Sanctions Tighten: OFAC Limits Cuba Travel

FDIC Proposes to Restructure Bank Resolution Planning Rules

Venezuela Sanctions Tighten: OFAC Sanctions the Venezuelan Central Bank and Senators Propose Sanctions Legislation

First Ever Criminal Bank Secrecy Act Charge Brought Against U.S. Broker-Dealer