PODCAST: Anti-Money Laundering and the New Beneficial Ownership Rule — C&M's Trump: The First Year Series
Client Alert | 1 min read | 06.22.17
What does the new beneficial ownership rule mean for lenders and other businesses? As part of our “Trump: The First Year” series, International Trade Group partners Carlton Greene and Cari Stinebower sit down with Commercial Finance & Lending Senior Counsel Scott Lessne to discuss the new rule. Prior to joining the firm in 2015, Carlton served as chief counsel of FinCEN and also worked for OFAC at the Dept. of the Treasury. Cari has previously worked as an attorney advisor for the Office of the General Counsel at OFAC. Scott's practice involves the representation of financial institutions and corporate clients in connection with the negotiation and documentation of commercial, asset-based, project-related, and real estate loan transactions.
Discussed in this 33 minute podcast:
- An overview of the new CDD rule, including what is covered.
- How can banks identify beneficial owners? Who is responsible?
- How does this affect small institutions versus large ones?
- What new technology might affect this space?
- What do covered businesses need to know and do?
Click below to listen or access from one of these links:
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On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future.
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