On Dec. 22, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule (Access Rule) establishing the parameters for authorized access to BOI reportedContinue Reading FinCEN Publishes Final Rule on Access to Beneficial Ownership Information
Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations, and anti-money laundering (AML) and international corruption matters.
Kyle was one of 19 prosecutors selected by Robert S. Mueller III to conduct the high-profile investigation into alleged Russian election interference, coordination between Russian officials and the Trump campaign, and related matters. As Assistant Special Counsel, Kyle played a lead role in federal tax and bank fraud investigations, as well as a money laundering investigation into the funding of Russian intelligence cyber intrusions during the 2016 Presidential election using cryptocurrency.
While at the Department of Justice, Kyle was involved in investigations relating to major international money laundering and corruption matters, including matters involving the Bank Secrecy Act (BSA), Foreign Corrupt Practices Act (FCPA), and foreign banking and corruption laws designated as predicates to U.S. money laundering charges. Kyle has considerable experience handling cross-border issues and coordinating with foreign law enforcement authorities and U.S. and foreign regulators on complex transnational financial cases.
Kyle has also represented dozens of federal agencies in high-profile litigation, including the Office of Foreign Assets Control (OFAC), the Department of Defense, and the Federal Financing Bank. Kyle has appeared before federal trial courts across the country.
‡ Admitted in California. Practice in the District of Columbia limited to matters and proceedings before Federal courts and Agencies.
Starting Jan. 1, 2024, the Corporate Transparency Act and its implementing regulations mandate that certain U.S. legal entities and foreign entities registered to do business in the United States (collectively…Continue Reading Corporate Transparency Act Takes Effect with Beneficial Ownership Reporting Requirements
Starting Jan. 1, 2024, the CTA mandates that certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) report certain BOI…Continue Reading FinCEN Updates Frequently Asked Questions on Beneficial Ownership Reporting Rule Ahead of Jan. 1, 2024, Effective Date
Effective Jan. 1, 2024, the Corporate Transparency Act (CTA) will require certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) to…Continue Reading FinCEN Extends Beneficial Ownership Reporting Deadline for Newly Formed Companies
On Oct. 23, 2023, FinCEN published an NPRM that identifies international CVC mixing as “a class of transactions of primary money laundering concern,” and finds that imposing additional recordkeeping and…Continue Reading FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing
The Corporate Transparency Act of 2019 (CTA), enacted as part of the Anti-Money Laundering Act of 2020, requires, for the first time, that certain U.S. legal entities and foreign entities…Continue Reading Corporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting Requirements
On April 18, 2023, Department of Commerce Assistant Secretary for Export Enforcement Matthew Axelrod issued a memorandum (Memorandum) that, while primarily focused on enforcement of export control restrictions, offered some…Continue Reading Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce Insights
On Dec. 15, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking implementing the provisions of the Corporate Transparency Act that…Continue Reading FinCEN Proposes Rule on Access to Beneficial Ownership Information
On Dec. 13, 2022, the Department of Justice announced that Danish global financial institution Danske A/S (Danske Bank) pled guilty and agreed to forfeit $2 billion to resolve an investigation…Continue Reading Danske Bank Pleads Guilty, Agrees to Pay More Than $2 Billion in Coordinated Resolution of Investigations into Fraud Related to Its Anti-Money Laundering Controls
On Sept. 29, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule, effective Jan. 1, 2024, implementing the beneficial ownership information reporting…Continue Reading Beneficial Ownership Reporting Requirements: FinCEN Issues Final Rule for Implementation of Corporate Transparency Act