On March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama found the Corporate Transparency Act (CTA or Act) unconstitutional on the
Continue Reading District Court Declares Corporate Transparency Act UnconstitutionalMarina Olman-Pal
Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.
FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting Requirements
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has long recognized non-financed (i.e., “all-cash”) transfers of residential real estate as susceptible of money laundering because these methods…
Continue Reading FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting RequirementsHawaii’s Money Transmitters Modernization Act Will No Longer Apply to Cryptocurrency Activities
On Jan. 25, 2024, the Hawaii Department of Commerce and Consumer Affairs Division of Financial Institutions (DFI) and the Hawaii Technology Development Corporation (collectively, the “Agencies”) jointly issued a press…
Continue Reading Hawaii’s Money Transmitters Modernization Act Will No Longer Apply to Cryptocurrency ActivitiesFDIC Issues Cease and Desist Letters to 5 Entities for Making False or Misleading Representations Regarding Deposit Insurance
On Jan. 19, 2024, the Federal Deposit Insurance Corporation (FDIC) issued letters demanding five entities and certain associated parties cease and desist from making false and misleading statements about FDIC…
Continue Reading FDIC Issues Cease and Desist Letters to 5 Entities for Making False or Misleading Representations Regarding Deposit InsuranceFinCEN Publishes Final Rule on Access to Beneficial Ownership Information
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 reported…
Continue Reading FinCEN Publishes Final Rule on Access to Beneficial Ownership InformationCorporate Transparency Act Takes Effect with Beneficial Ownership Reporting Requirements
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 RequirementsFinCEN Updates Frequently Asked Questions on Beneficial Ownership Reporting Rule Ahead of Jan. 1, 2024, Effective Date
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 DateNew Florida Legislation Proposes Notification Requirements for Certain Financial Institutions When They Terminate, Suspend, or Take Similar Action to ‘Restrict’ Customer Account Access
On Nov. 20, 2023, Florida Rep. Bob Rommel (R-Naples) introduced Florida House Bill 585, which proposes to require certain financial institutions operating in Florida to file a “termination-of-access report” with…
Continue Reading New Florida Legislation Proposes Notification Requirements for Certain Financial Institutions When They Terminate, Suspend, or Take Similar Action to ‘Restrict’ Customer Account AccessFinCEN Extends Beneficial Ownership Reporting Deadline for Newly Formed Companies
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 CompaniesCFPB Unveils Plan to Supervise Big Tech Digital Wallet and Payment App Providers
On Nov. 7, 2023, the Consumer Financial Protection Bureau (CFPB) released a proposed rule that would, if finalized in its present form, establish the CFPB’s supervisory authority over certain “larger…
Continue Reading CFPB Unveils Plan to Supervise Big Tech Digital Wallet and Payment App Providers