Ballard Spahr LLP (LexBlog Andorra)
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A “Death Sentence” for Financial Institutions: the D.C. Circuit Dismisses Andorran Bank Shareholders’ Challenge to FinCEN’s Imposition of a Special Measure Under Section 311
On May 23, the federal court of appeals for the District of Columbia Circuit rejected an appeal by the majority shareholders in Banca Privada d’Andorra S.A. (“BPA”) regarding claims that FinCEN violated the Administrative Procedure Act when issuing a March 2015 Notice of Finding that the Andorran bank was a financial institution “of primary money...
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