Ramon Cierco v. Steven Mnuchin
Court of Appeals for the D.C. Circuit
1Opinion of the Court
EDWARDS, Senior Circuit Judge:
In 2015, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) suspected that Banca Privada d’Andorra S.A. (“the Bank”) was being used to launder money. Pursuant to Section 311 of the USA PATRIOT Act, Fin-CEN issued a Notice of Finding and a Notice of Proposed Rulemaking (the “Notices”) proposing to cut off the Bank’s ties to the United States’ financial system. Without completing the rulemaking process that these Notices contemplated, Fin-CEN effectively achieved its goals when the Andorran Government seized the assets of the Bank and…
2Cases cited30 opinions
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- City of Los Angeles v. LyonsSupreme Court of the United States · 1983
- Allen v. WrightSupreme Court of the United States · 1984
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