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 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 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
Key Takeaway: Following a court decision on February 18, 2025, the Corporate Transparency Act’s (CTA) beneficial ownership reporting requirements are once again in effect. Most companies will have until Friday, March 21,...more
2/20/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements ,
Small Business
“Can you create a New York driver’s license for a John Brown with brown hair and brown eyes, 5’11”, 200 lbs, living at 123 State Street in New York? Also, a bank statement from XYZ Bank displaying $235,887 in the account,...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 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 16, 2024, the U.S. Department of Justice (DOJ) announced a plan to reschedule marijuana under the Controlled Substances Act (CSA) from a schedule I to a schedule III controlled substance. The Attorney General and the...more
7/24/2024
/ Anti-Money Laundering ,
Banking Acts ,
Controlled Substances Act ,
DEA ,
Decriminalization of Marijuana ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Marijuana ,
Proposed Rules
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
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 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 September 29, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing beneficial ownership requirements for certain U.S. and foreign entities registered to do business in the United States,...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 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (NPRM or “Proposed Rule”) to implement the beneficial ownership information (BOI) reporting provisions of the...more
1/4/2022
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Creditors ,
Customer Due Diligence (CDD) ,
Exceptions ,
Financial Action Task Force ,
FinCEN ,
Inheritance ,
Notice of Proposed Rulemaking (NOPR) ,
Ownership Interest ,
Ownership Rules ,
Reporting Requirements ,
U.S. Treasury
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
As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more
6/9/2021
/ Anti-Money Laundering ,
Arbitration ,
Artificial Intelligence ,
Banking Sector ,
Bostock v Clayton County Georgia ,
BSA/AML ,
Carbon Emissions ,
Climate Change ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Cybersecurity ,
Department of Education ,
Department of Homeland Security (DHS) ,
Eviction ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
FinCEN ,
FRB ,
FSOC ,
HOLA ,
Landlords ,
Mortgages ,
NYDFS ,
OCC ,
Popular ,
Student Loans ,
TCPA ,
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