On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more
7/23/2025
/ AML/CFT ,
Anti-Money Laundering ,
Banks ,
BSA/AML ,
Effective Date ,
Final Rules ,
FinCEN ,
Investment Management ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
SAR ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
Designed for busy in-house counsel and compliance professionals, this newsletter summarizes some of the most important domestic and international Anti-Money Laundering (AML) regulatory and enforcement developments from the...more
7/17/2025
/ Anti-Money Laundering ,
Cartels ,
China ,
Enforcement Actions ,
EU ,
European Commission ,
Executive Orders ,
Financial Crimes ,
FinCEN ,
FOFA Reforms ,
International Trade ,
Mexico ,
Money Laundering ,
Regulatory Requirements ,
Switzerland ,
Terrorist Organizations ,
U.S. Treasury
On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more
7/8/2025
/ Bank Secrecy Act ,
Banks ,
BSA/AML ,
Customer Identification Program (CIP) ,
Data Collection ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Money Services Business ,
New Regulations ,
Patriot Act ,
Regulatory Reform ,
Social Security Numbers ,
Taxpayer Identification Number ,
Third-Party ,
U.S. Treasury
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 March 26, 2025, the House Financial Services Committee Subcommittee on Financial Institutions held a hearing, entitled “A New Era for the CFPB: Balancing Power and Reprioritizing Consumer Protections.”...more
On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more
On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more
3/17/2025
/ Anti-Money Laundering ,
Cartels ,
Currency Transaction Reports (CTR) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
FinCEN ,
Money Laundering ,
Popular ,
Reporting Requirements ,
U.S. Treasury
On December 26, 2024, a merits panel of the United States Court of Appeals for the Fifth Circuit contributed to the frenzied whirlpool of Corporate Transparency Act (CTA) developments, reversing an earlier decision to stay...more
In a recent client alert, we notified clients that on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction against enforcement of the Corporate Transparency Act (CTA) and...more
As detailed in our client alert regarding the issuance of a preliminary injunction by the Eastern District Court of Texas against the Corporate Transparency Act (CTA), enforcement of the CTA and its reporting rules on...more
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction against enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI)...more
Key Takeaways -
•FinCEN has issued two new final rules to significantly expand regulation around certain investment adviser and residential real estate sectors to combat illicit finance in these areas. These highly...more
9/26/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Popular ,
Real Estate Transfers ,
Registered Investment Advisors ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue...more
8/7/2024
/ BSA/AML ,
CFTC ,
Corruption ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
FinCEN ,
Healthcare Fraud ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On July 19, 2024, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the “Agencies”)...more
On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more
7/8/2024
/ AML/CFT ,
Bank Secrecy Act ,
Customer Identification Program (CIP) ,
Exempt Reporting Advisers (ERAs) ,
FinCEN ,
Investment Adviser ,
Investment Management ,
NPRM ,
Popular ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
On March 7, 2024, during her keynote remarks at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new Department of Justice (DOJ) Criminal Division...more
3/19/2024
/ Asset Recovery ,
CFTC ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Non-Prosecution Agreements ,
Pilot Programs ,
Self-Reporting ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On February 16, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking, which would require certain real estate professionals to report certain transaction information to FinCEN in...more
In July 2020, a sensitive Federal Bureau of Investigation (FBI) document was leaked to the public. The document outlined the FBI’s suspicions that the private investment funds industry was providing choice money laundering...more
This client alert is an update to an earlier MoFo client alert issued on December 8, 2022. In a final rule implementing the Corporate Transparency Act (the “Final Rule”), the Financial Crimes Enforcement Network (“FinCEN”)...more
2/15/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
Legal Entity Identifiers ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
Popular ,
Real Estate Investments ,
Regulatory Requirements ,
REIT ,
Reporting Requirements
On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued final rules establishing a framework for accessing, using, and protecting beneficial ownership information (BOI)...more
1/22/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
FinCEN ,
Foreign Corporations ,
Intelligence Services ,
Law Enforcement ,
National Security ,
Reporting Requirements
In 2021, Congress passed the Corporate Transparency Act (CTA), which is designed to bring the U.S. into compliance with international anti-money laundering (AML) standards. The CTA is aimed at combatting anonymous shell...more
On November 8, 2023, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published a final rule detailing when and how reporting companies can use another entity’s FinCEN identifier in place of...more
Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more
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
Under a final rule (the “Final Rule”) recently issued by the Financial Crimes Enforcement Network (“FinCEN”), beginning January 1, 2024, entities that own and operate U.S. real estate must report their “Beneficial Owners”—the...more