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For the last several months, Arnold & Porter has been tracking the Department of Justice's announcements of fraud cases involving the alleged misappropriation of funds provided by the Coronavirus Aid, Relief, and Economic Security Act.

Congress is expected to include a significant reform to the US anti-money laundering framework in the National Defense Authorization Act for Fiscal Year 2021 (NDAA), one of the last major bills lawmakers are likely to pass this year.

The enactment of the CTA in 2021 came as a shock to many (to some, a much later aftershock).

On May 20, 2022, the US Securities and Exchange Commission settled charges against a dually registered broker-dealer and investment adviser, which also is a subsidiary and nonbank affiliate of...

Financial institutions of all sizes were levied with high fines over the past few years due to non-compliance with anti-money laundering requirements resulting in increased supervisory attention on BSA/AML regulations by federal banking agencies.

The Corporate Transparency Act ("CTA"), which came into force on 1 January 2024, brings the US into a new era of beneficial ownership information ("BOI") compliance, in line with international...

Today, the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN") issued a final rule aimed to ease compliance with certain aspects of the regulations promulgated...

As noted in our post summarizing last week's National Forum on the Foreign Agents Registration Act (FARA), much of the discussion at the conference focused on DOJ's recent...

On February 26, 2020, a Connecticut federal judge overturned a former Alstom SA executive's foreign bribery convictions after finding that prosecutors had failed to prove that the defendant

The summer of 2017 saw the U.S. Department of Justice's docket still teeming with Foreign Corrupt Practices Act (FCPA) cases.

In an opinion published on October 8, 2025, the Second Circuit vacated an order of forfeiture, holding that defendant Matt Elias could not be ordered to forfeit property...

The U.S. Department of Labor announced last week OSHA will oversee the processing of worker retaliation complaints filed under two new whistleblower statutes...

The Financial Crimes Enforcement Network ("FinCEN") recently waded into unexpected controversy with the release of proposed data fields for the beneficial ownership information ("BOI")...

On September 7, 2018, after considerable industry feedback and two issuances of temporary relief, the Financial Crimes Enforcement Network (FinCEN) ...

A broker-dealer settled FINRA charges of failing to establish and implement a reasonable AML program after the firm's surveillance system generated inaccurate and incomplete reports.

On March 27, 2019, Cadwalader presented a webinar on recent anti-money laundering ("AML") developments affecting cannabis businesses, broker-dealers, blockchain transactions and draft legislation.

The Federal Reserve has proposed updates to its anti-money laundering and countering the financing of terrorism program requirements for supervised banks, largely aligning with earlier reforms proposed by FinCEN and other banking regulators. However, the Federal Reserve's proposal notably omits provisions requiring consultation with FinCEN before significant supervisory actions, raising questions about regulatory coordination and the practical implications of the new "significant or systemic" enforcement th

Under U.S. law, FinCEN is authorized to issue orders imposing additional recordkeeping and reporting requirements on domestic financial institutions or non-financial trades or businesses in a geographic area.