On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more
7/8/2025
/ Anti-Money Laundering ,
Cartels ,
CFIUS ,
China ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Foreign Agents Registration Act (FARA) ,
Mexico ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury
On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its first “Gap Rule” enforcement action in a Consent Order with Bancrédito International Bank and Trust...more
9/26/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bribery ,
Consent Order ,
Enforcement Authority ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Puerto Rico ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
U.S. Treasury
On July 31, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMS) issued a risk alert summarizing observations from its recent anti-money laundering (AML) and counter-financing of terrorism...more
On Friday, FinCEN published an Advance Notice of Proposed Rulemaking (ANPRM) as it further considers implementing a no-action letter process related to anti-money laundering compliance. The ANPRM follows a 2021 FinCEN...more
The past year has seen a flurry of crypto-related activities by the federal financial regulators, including the issuance of reports, guidance, joint statements, and interpretive letters....more
5/5/2022
/ Anti-Money Laundering ,
Blockchain ,
Corporate Counsel ,
Cryptocurrency ,
Department of Financial Services ,
Executive Orders ,
FDIC ,
Know Your Customers ,
NYDFS ,
OCC ,
Popular ,
Stablecoins ,
Virtual Currency
On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more
12/16/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corruption ,
Financial Action Task Force ,
FinCEN ,
GTO ,
Popular ,
Real Estate Market ,
SAR ,
Title Insurance ,
Transaction Reporting ,
U.S. Treasury
Following the enactment of the Anti-Money Laundering Act of 2020 (AMLA), which encompasses the Corporate Transparency Act (CTA), the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed...more
As part of the Office of the Comptroller of the Currency’s (OCC) declared effort to keep pace with a mounting demand for faster, cheaper, and more efficient payments, and the widespread adoption of new technologies, the...more
1/18/2021
/ Anti-Money Laundering ,
Banks ,
Blockchain ,
Comptroller ,
Cryptocurrency ,
Electronic Payment Transactions ,
Federal Savings Associations ,
Financial Institutions ,
Interpretive Letters ,
OCC ,
Popular ,
Stablecoins
On New Year’s Day, Congress overrode President Trump’s veto of the National Defense Authorization Act (NDAA) for the 2021 fiscal year, turning the bill into law without requiring the president’s signature. The NDAA includes...more
1/13/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Civil Monetary Penalty ,
FinCEN ,
Foreign Banks ,
NDAA ,
Patriot Act ,
Popular ,
Presidential Veto ,
Reporting Requirements ,
Secretary of the Treasury
On September 17, 2020, the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed Rulemaking (ANPR) in the Federal Register, seeking comments on how to improve the effectiveness of anti-money...more
On July 22, 2019, the five federal agencies tasked with the supervision, examination, and enforcement of Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements for banks (the “Agencies”) issued a joint statement...more
On December 3, 2018, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network (“FinCEN”), National Credit Union Administration, and Office of the...more
EDITOR’S NOTE -
In like a lion, out like a lamb—it works for weather; does it work for new administrations? We’ll have to wait and see. We’ll have to wait and see about the length of CFPB Director Richard Cordray’s...more
3/20/2017
/ Anti-Money Laundering ,
Arbitration Agreements ,
Bank Fraud ,
Bank Holding Company Act ,
Banking Sector ,
Banks ,
Civil Monetary Penalty ,
Consumer Financial Protection Bureau (CFPB) ,
Criminal Prosecution ,
Data Security ,
Distributed Ledger Technology (DLT) ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Forfeiture ,
NIST ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Opt-In ,
Overdraft Fees ,
Preemption ,
Shaw v United States ,
Student Loans ,
TCPA ,
TLAC ,
True Lender
On May 11th, 2016, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the Treasury, published a Final Rule (the “Rule”) on customer due diligence after a four-year rulemaking process. The Rule...more
The Financial Action Task Force (“FATF”) recently released a white paper entitled “Guidance for a Risk Based-Approach: Prepaid Cards, Mobile Payments and Internet-based Payment Services” (“Guidance”). The Guidance contains...more