Recently, FinCEN has taken steps to implement two new regulatory regimes designed to address national security threats in modern financial transactions, one dealing with digital currency and one imposing new beneficial ownership reporting requirements. In a guest article, Mario Mancuso and Sanjay Mullick, partners at Kirkland & Ellis, along with Carrie Schroll, an associate at the firm, take a quick look at those developments and provide key takeaways. See “Cryptocurrency and Corruption: The Future of FCPA Enforcement?” (Mar. 31, 2021).
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