On March 7, 2024, U.S. Deputy Attorney General Lisa Monaco gave remarks at the American Bar Association’s 39th National Institute on White Collar Crime in San Francisco, California. Monaco provided updates on the U.S. Department of Justice’s (DOJ or the Department) corporate criminal enforcement efforts and announced a handful of new Department initiatives, including a new DOJ whistleblower program that gives monetary rewards for whistleblowers in cases that lead to criminal or civil forfeiture.

On March 1, 2024, the United States District Court for the Northern District of Alabama declared the Corporate Transparency Act (“CTA”) unconstitutional.  Enacted as part of the Anti-Money Laundering Act of 2020, the CTA requires certain legal entities to report beneficial ownership information (“BOI”) to the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”).  The reporting provisions took effect on January 1, 2024.  In National Small Business United v. Yellen (5:22-cv-01448-LCB), the District Court, in a memorandum opinion, rejected the Government’s position when it held that the CTA exceeds Congress’ power to regulate these business entities. The Court issued a Final Judgment on March 1st as well, permanently enjoining enforcement of the CTA against the two plaintiffs.