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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:
PodBean | SoundCloud | iTunes

Insights

Client Alert | 5 min read | 12.12.25

Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality

On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument....