On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued three orders designating CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. (collectively,...more
7/3/2025
/ Anti-Money Laundering ,
Banks ,
Criminal Investigations ,
Drug Trafficking ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Mexico ,
Money Laundering ,
Opioid ,
U.S. Treasury
On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more
6/12/2025
/ Bribery ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Trump Administration ,
White Collar Crimes
In a significant move to curb illegal activities at the U.S. Southwest border, the Financial Crimes Enforcement Network (FinCEN) issued an alert, on May 1, 2025, concerning oil smuggling from Mexico into the United States,...more
On May 1, 2025, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) regarding the Huione Group, a foreign financial institution located in Cambodia. This proposal, enacted under...more
5/6/2025
/ AML/CFT ,
Cambodia ,
Cryptocurrency ,
Cyber Crimes ,
Digital Assets ,
Enforcement Actions ,
Financial Crimes ,
Financial Services Industry ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Know Your Customers ,
Money Laundering ,
NPRM ,
Patriot Act ,
Popular ,
Proposed Rules
In a significant policy shift, Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation By Prosecution,” on April 7, 2025, signaling a change in the Department of Justice’s (DOJ) approach to digital...more
4/16/2025
/ Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Financial Crimes ,
Investment ,
National Security ,
Regulatory Reform ,
Securities Regulation ,
Trump Administration
On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking,...more
On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more
On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more
2/25/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Examinations ,
BSA/AML ,
Consumer Financial Products ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
OCC ,
Prepaid Payment Products ,
Regulatory Violations ,
Risk Management
Brinks Global Services USA (“BGS USA”), a global leader in secure logistics, found itself at the center of a significant regulatory investigation due to its failure to meet anti-money laundering (“AML”) obligations....more
Although the scope of federal antitrust enforcement under the second Trump administration remains uncertain, the Procurement Collusion Strike Force (PCSF) is expected to remain active. The PCSF, which was started by the first...more
2/12/2025
/ Antitrust Division ,
Antitrust Provisions ,
Antitrust Violations ,
Bribery ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Contractors ,
Federal Procurement Systems ,
Federal Trade Commission (FTC) ,
Monopolization ,
Price-Fixing ,
Procurement Guidelines ,
Public Procurement Policies ,
Sherman Act ,
Trump Administration
In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more
12/6/2024
/ Blockchain ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Money Transmitter ,
Office of Foreign Assets Control (OFAC) ,
Open Source Software ,
SDN List ,
Smart Contracts ,
U.S. Treasury ,
Virtual Currency
On October 22, 2024, the U.S. Court of Appeals for the Second Circuit ruled that Türkiye Halk Bankası A.Ş. (“Halkbank”), owned by the Republic of Turkey, can be prosecuted for allegedly helping Iran evade U.S. sanctions and...more
10/28/2024
/ Bank Fraud ,
Corporate Counsel ,
Corruption ,
Financial Transactions ,
Foreign Sovereign Immunities Act of 1976 (FSIA) ,
Indictments ,
Iran ,
Iran Sanctions ,
Money Laundering ,
Money Services Business ,
Sanction Violations ,
Sovereign Immunity ,
Turkey ,
White Collar Crimes
On August 27, 2024, the New York State Department of Financial Services (“NYDFS”) announced a consent order involving a $35 million settlement with Nordea Bank Abp (“Nordea”) for alleged significant failures related to...more
9/5/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Consent Order ,
Due Diligence ,
Financial Institutions ,
Financial Services Industry ,
Money Laundering ,
NYDFS ,
Panama Papers
On June 20, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplemental advisory to alert U.S. financial institutions about emerging trends in the illicit fentanyl supply chain. The supplemental advisory...more
7/3/2024
/ Bank Secrecy Act ,
BSA/AML ,
Department of Justice (DOJ) ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Illegal Drugs ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Prescription Drugs ,
Significant Transnational Criminal Organization ,
Supply Chain
On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more
5/8/2024
/ AML/CFT ,
Anti-Money Laundering ,
Banks ,
BSA/AML ,
Due Diligence ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
OCC ,
Risk Assessment ,
Risk Management ,
Third-Party ,
Third-Party Risk
It is challenging for law enforcement to track down and trace illicit activities conducted through digital currencies. The process can be very time- and resource-intensive. Further, securing charges and arrests, and...more
3/19/2024
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Daubert Standards ,
Digital Assets ,
Digital Currency ,
Electronic Communications ,
Enforcement Actions ,
Evidence ,
Expert Testimony ,
Financial Crimes ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
Government Investigations ,
Guilty Pleas ,
Money Laundering ,
Popular ,
Virtual Currency
The Financial Crimes Enforcement Network (“FinCEN”) recently released a Financial Trend Analysis (“FTA”) focusing on identity-related suspicious activity. The FTA was issued pursuant to section 6206 of the Anti-Money...more
Summary -
The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more
12/6/2023
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Corporate Crimes ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
FCPA Corporate Enforcement Policy (CEP) ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Money Laundering ,
White Collar Crimes
On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more
11/1/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Convertible Virtual Currencies (CVCs) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
NPRM ,
Recordkeeping Requirements ,
Virtual Currency
Summary -
Deputy Attorney General Lisa O. Monaco unveiled Wednesday, Oct. 4, the Department of Justice’s (DOJ) new safe harbor policy for voluntary self-disclosures (VSD) arising from mergers and acquisitions (Safe Harbor...more
Complex Civil and Criminal Cases Converge -
On August 17, 2023, Judge Robert Pitman of the federal district court for the Western District of Texas issued an Order granting summary judgment for the U.S. Treasury Department...more
8/30/2023
/ Administrative Procedure Act ,
Decentralized Autonomous Organization (DAO) ,
Department of Justice (DOJ) ,
Digital Assets ,
Economic Sanctions ,
Fifth Amendment ,
FinCEN ,
First Amendment ,
Free Speech ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Money Transmitter ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Takings Clause ,
U.S. Treasury ,
Virtual Currency
On April 19, 2023, the United States Supreme Court issued a highly-anticipated decision in the case of Turkiye Halk Bankasi A.S., aka Halkbank v. United States. The court ruled that Turkish state-owned Halkbank remained...more
The U.S. Department of Justice (“DOJ”) announced on March 15, 2023 that in a coordinated effort between U.S. Federal Bureau of Investigations, Europol, and German police, the darknet cryptocurrency mixing service ChipMixer...more
On January 4, 2023, the New York State Department of Financial Services (“NYDFS”) issued a consent order against Coinbase, Inc. (“Coinbase” or the “Company”), the largest U.S.-based cryptocurrency trading exchange, for...more
First Post in a Two-Post Series on the CTA Implementing Regulations -
On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued its final rule, Beneficial Ownership Information Reporting...more