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
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
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 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
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
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
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
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
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
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
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 October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more
Government Alleges Systemic and Deliberate AML Failures -
Filings Describe Tools for CVC Exchanges to Use for Customer Due Diligence and Transaction Monitoring -
The Financial Crimes Enforcement Network (“FinCEN”) and...more
Seventh Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
On April 5, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued an advance notice of proposed rulemaking (“ANPRM”) to...more