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 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
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
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
The Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a joint alert on June 28, 2022, warning of evasion attempts by individuals or entities to...more
Case Highlights the Role of Correspondent Bank Accounts and Circumvention of AML Programs -
Court Order Describes Seizure as a “Reckoning” for Atrocities in the Ukraine...more
On January 13, 2022, Himamauli “Him” Das, the Acting Director of FinCEN, virtually addressed the Financial Crimes Enforcement Conference hosted by the American Bankers Association and the American Bar Association. In his...more
On February 25, 2021, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to the Bank Secretary Act/Anti-Money Laundering (“BSA/AML”) Examination Manual (the “Manual”), which provides guidance to...more
Court Rejects Halkbank’s Claim That the Foreign Sovereign Immunities Act Shields the Bank From Prosecution -
A motion to dismiss an indictment accusing Turkey’s majority state-owned Halkbank of money laundering, bank...more
10/20/2020
/ Commercial Activity Exception ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Extraterritoriality Rules ,
Financial Institutions ,
Foreign Sovereign Immunities Act of 1976 (FSIA) ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
Iran Sanctions ,
Legislative History ,
Money Laundering ,
Personal Jurisdiction ,
Sovereign Immunity ,
State-Owned Enterprises ,
U.S. Treasury