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
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
On April 1, 2025, the House Financial Services Committee issued a press release regarding a number of Committee requests to various federal agencies for rescission, modification, or re-proposal of specific Biden...more
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
Since early December of last year, the CTA has been in a state of flux. As we recently reported, FinCEN announced it would delay the reporting deadline for most companies to March 21, 2025, and that it would provide any...more
On March 14, 2025, a judge in the U.S. District Court for the District of Maryland declined to grant a temporary injunction to the City of Baltimore and the Economic Action Maryland Fund. The plaintiffs had requested an...more
3/21/2025
/ Bank Secrecy Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
Military Lending Act ,
OCC ,
Regulatory Agenda ,
Stablecoins
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
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments.
This week, we review the following developments as of Wednesday:...more
On February 20, 2025, House Majority Leader Steve Scalise (R-La.) issued a list of priority regulatory targets for nullification under the CRA “in the coming weeks.” Included on the list is the CFPB’s December 10, 2024 final...more
On February 18, 2025, President Trump signed an Executive Order designed to reduce the power of federal independent agencies by bringing them under the purview of the White House. The Executive Order provides that it applies...more
2/21/2025
/ Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
CRA ,
Executive Orders ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulation Z ,
Regulatory Reform ,
Stablecoins ,
Trump Administration
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
On February 7, 2025, newly confirmed Office of Management and Budget (OMB) director Russell Vought replaced Treasury Secretary Scott Bessent as acting director of the CFPB....more
2/14/2025
/ CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Enforcement Actions ,
Federal Funding ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OMB ,
Regulatory Agenda
Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
2/7/2025
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Government Efficiency ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration
Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
2/3/2025
/ Artificial Intelligence ,
Central Bank Digital Currency (CBDCs) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
Financial Regulatory Reform ,
FinTech ,
OMB ,
Regulatory Freeze ,
Secretary of the Treasury ,
Securities and Exchange Commission (SEC) ,
Senate Confirmation Hearings ,
U.S. Treasury
On January 23, 2025, the U.S. Supreme Court granted the federal government’s motion to stay the nationwide injunction blocking the Corporate Transparency Act’s (CTA) enforcement, issued by the federal district court of the...more
On January 20, 2025, President Trump issued a Regulatory Freeze Pending Review (“Regulatory Freeze”) that applies to all executive departments and agencies. The Regulatory Freeze prohibits the proposal or issuance of any rule...more
1/27/2025
/ Artificial Intelligence ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
FDIC ,
Financial Services Industry ,
Hiring Freeze ,
Regulatory Freeze ,
Regulatory Reform ,
Rescission ,
Securities and Exchange Commission (SEC) ,
Trump Administration
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