Michael G. Sanders

Michael Sanders’ practice focuses on advising banking, financial services, and private equity clients on a broad range of transactional, regulatory, and enforcement matters.

Michael joined the firm in 2017.

Editorial Board, Virginia Law Review, University of Virginia School of Law

FinCEN Eliminates CTA Requirements for All U.S. Companies and U.S. Individuals
Trump Administration Proposes Eliminating CTA Requirements for All U.S. Companies
FinCEN Pauses All CTA Filing Obligations and Will Issue New Rules
Remaining Injunction Pausing Corporate Transparency Act is Lifted; FinCEN Extends General Filing Deadline to March 21; Statute’s Future Remains Uncertain
Trump Administration Continues Defense of Corporate Transparency Act, Indicates FinCEN’s Flexibility On Deadlines And Scope
U.S. Supreme Court Lifts Initial Injunction Against Enforcement Of Corporate Transparency Act, But A Separate Injunction Continues To Halt Implementation
Fifth Circuit Pauses District Court CTA Injunction; FinCEN Extends Filing Deadline to January 13, 2025
U.S. DOJ Seeks to Pause or Narrow Injunction Blocking CTA; District Court Orders Expedited Briefing
DOJ Appeals CTA Injunction; FinCEN Suspends Filing Requirement
Federal District Court Enjoins Enforcement of U.S. Corporate Transparency Act
FinCEN Imposes AML Program and SAR Filing Requirements on Investment Advisers
Another Step Towards Federal AML Obligations for Investment Advisers
OFAC Allows Venezuelan Oil and Gas Authorization to Expire and Extends Prohibitions to Execution on PdVSA 2020 Bond Collateral
FinCEN Tries Again . . . to Impose AML Requirements on Investment Advisers
Countdown to Implementation of US Beneficial Ownership Reporting
OFAC Eases Venezuela Sanctions Lifts Secondary Market Trading Ban on US Persons
FinCEN Proposes Rule Regarding Access to Beneficial Ownership Information under the Corporate Transparency Act
Preparing for Digital Asset Developments in 2023
OFAC and FinCEN Announce Joint Enforcement Action Against U.S.-Based Digital Asset Exchange
FINCEN’s Corporate Beneficial Ownership Reporting Rule: Significance for Investment Advisers
U.S. Treasury Adopts Final Corporate Beneficial Ownership Reporting Rule
FinCEN Proposes Corporate Beneficial Ownership Reporting Rule
FinCEN Requests Input on Potential AML Requirements for Real Estate Transactions
OFAC Ramps up Targeting of Ransomware-linked Actors and FinCEN Updates Ransomware Advisory
OFAC Issues Sanctions Guidance to Virtual Currency Industry
Cryptocurrency and Other New Forms of Financial Technology: Potential Terrorist Financing Concerns and Liability
OFAC Settles With Digital Currency Payment Processor for Sanctions Violations
OCC Affirms Authority of National Banks to Engage in Additional Cryptocurrency-Related Activities, Including Issuing Stablecoins
FDIC Finalizes Rule for Supervision of ILC Parents
Congress Overhauls AML Framework, Mandating Disclosure of Beneficial Ownership Information
Online Financial Service Companies: The Anti-Terrorism Act’s Next Frontier
FDIC Approves Two New ILCs and Proposes Supervision of ILC Parents
District Court Decision Incorrectly Holds that OFAC Sanctions Bar PdVSA
United States Designates the Government of Venezuela for Blocking Sanctions
Cuba Sanctions Tighten: OFAC Limits Cuba Travel
FDIC Proposes to Restructure Bank Resolution Planning Rules
Venezuela Sanctions Tighten: OFAC Sanctions the Venezuelan Central Bank and Senators Propose Sanctions Legislation
First Ever Criminal Bank Secrecy Act Charge Brought Against U.S. Broker-Dealer

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Michael G. Sanders

Associate

Washington, D.C.