Davis Polk partner Dan Stipano was quoted in MoneyLaundering.com from a panel at ACAMS’ AML & Financial Crime Conference, during which he discussed the 24 types of entities that the Corporate Transparency Act (CTA) exempted from a planned FinCEN database of ownership information. He said one exemption in particular “presents a very effective roadmap” that money launderers and criminal organizations may use to sidestep the reporting requirements. Dan noted that while FinCEN may have some flexibility to refine the exemptions, it cannot regulate them out of existence.

Months Before Latest Leak, US Bill Created Potential Money Laundering Loophole,” MoneyLaundering.com (October 4, 2021) (subscription required)