FinCEN Assesses Civil Money Penalty Against Unregistered Money Transmitter

Full News Release

The Financial Crimes Enforcement Network (FinCEN) assessed civil penalties totaling $40,000 against two brothers for non-compliance with Bank Secrecy Act (BSA) money transmitter registration requirements. The brothers, doing business as Halal Depot of Wyoming, Michigan operated a money transmission business at their grocery store by sending funds on behalf of their customers to beneficiaries in Yemen, Somalia, Sudan, Kenya, Saudi Arabia, Uganda, Ethiopia, Qatar, Europe and the United Arab Emirates. At no time did the Sufi brothers register with FinCEN as a money services business (MSB) as required by the BSA.

FinCEN Assesses Civil Money Penalty Against Oregon-Based Unregistered Money Transmitter

Full Announcement.

The Financial Crimes Enforcement Network (FinCEN) today announced assessment of a $25,000 civil money penalty against Victor Kaganov of Tigard, Oregon, for violating Bank Secrecy Act (BSA) requirements for money transmitters. FinCEN determined that Kaganov violated BSA registration, anti-money laundering program, and suspicious activity reporting requirements while conducting an independent money transmitter business from his residence.

From July 2002 through March 2009, Kaganov conducted more than 4,200 funds transfers in the United States, involving total dollars amounting to more than $172 million, to and from a number of locations in Europe and Asia.

See also:
Department of Justice Press Release
FBI News Story March 7, 2011

Patent Joint Ownership Issue

Joint ownership can arise from joint inventorship, such as where two or more individuals directly or indirectly collaborate as inventors. This often times happens unwittingly, as the two inventors may not have worked on the development of the invention together or at the same time. Sometimes, the primary inventor does not realize that the other inventor’s contribution raises that individual to the level of inventor. This is because the inventors do not have to make the same type or amount of contribution and the inventors do not have to contribute to every claim in the patent application.

Ethicon was the exclusive licensee of the “sole” inventor of the patent and Ethicon sued U.S. Surgical for infringement. U.S. Surgical investigated and located a “missing” (ie. unnamed) joint inventor and then proceeded to negotiate a license from him. Ethicon challenged the validity of the license. The courts upheld the validity of the license because the “missing” inventor, as a joint inventor, was a joint owner of the entire patent. Ethicon v. U.S. Surgical Corp., 135 F.3d 1456 (Fed. Cir. 1998), cert. denied, 525 U.S. 923 (1998).

The cautionary tale here is that even a one percent contributor to a patent will be a joint owner of the entire patent. An owner of a patent who believes that he has exclusive control of the patent may be sadly mistaken and find himself suddenly competing with another company.

The key for the “sole” inventor is to make sure that all others (ie. employees, etc.) who may work on any aspect of the invention have valid employement agreements or valid joint venture agreements that contain the proper assignment clauses. These agreements must be entered into prior to any work by the employee or contractor.

For the purchaser of a patent, proper due diligence will be key to understanding where the potential risks may arise. Due diligence should include review of agreements with employees or contractors working on the development of the intellectual property. Drafting strong purchase agreements and transaction documents can help protect the purchaser. Effective guarantees, warranties, indemnification and assignment clauses can lessen the financial impact, if something unpleasant occurs following the purchase of the intellectual property.

FREE Non-Profit Company Information

The Nonprofit Association of Oregon

This association is a statewide network that provides resources to nonprofit organizations.  They provide training, classes, and other resources.

 Web Site:

 They also publish a great handbook titled The Oregon Nonprofit Corporation Handbook.  This is highly recommended for all non-profit clients.

Print copies may be available at:

5100 SW Macadam Avenue, Suite 360
Portland, Oregon 97239
P: 503-239-4001

 Please call to confirm pricing and that they have copies available.

Oregon Secretary of State

The forms for incorporating your nonprofit can be found at:

The Secretary of State also has a resource page for nonprofits: