On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more
7/23/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Biden Administration ,
BSA/AML ,
Compliance ,
Customer Identification Program (CIP) ,
Final Rules ,
Financial Regulatory Reform ,
FinCEN ,
Investment Adviser ,
Registered Investment Advisors ,
Regulatory Reform ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more
6/30/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Broker-Dealer ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Mexico ,
New Legislation ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more
6/24/2025
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Cayman Islands ,
Compliance Dates ,
Customer Identification Program (CIP) ,
Filing Requirements ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Investment Management ,
Patriot Act ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Regulatory Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
Last Friday, the U.S. Department of Justice (DOJ) unsealed its first indictment against a foreign national for providing material support to a Mexican drug cartel that the current administration recently designated a foreign...more
5/22/2025
/ Bank Secrecy Act ,
Cartels ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Financial Crimes ,
FinCEN ,
Indictments ,
Mexico ,
Money Laundering ,
National Security ,
SAR ,
Terrorism Funding ,
Trump Administration
On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more
10/15/2024
/ Bank Secrecy Act ,
Banks ,
BSA/AML ,
Department of Justice (DOJ) ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
OCC ,
Popular ,
Professional Disciplinary Actions ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
In response to illicit finance risks identified in the U.S. residential real estate sector, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced the issuance of its long-anticipated...more
9/3/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficiaries ,
BSA/AML ,
Final Rules ,
FinCEN ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Trusts ,
U.S. Treasury
On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more
9/3/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Customer Identification Program (CIP) ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Patriot Act ,
Popular ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
On May 13, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a joint notice of a proposed rulemaking (NPRM) that would require...more
On Feb. 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM)1 in response to illicit finance risks identified in the U.S. residential real estate...more
The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a notice of proposed rulemaking (NPRM) that would subject registered investment advisers (RIAs) and exempt reporting...more
2/16/2024
/ AML/CFT ,
Bank Secrecy Act ,
Customer Due Diligence (CDD) ,
FinCEN ,
Investment Adviser ,
NPRM ,
Patriot Act ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
U.S. Treasury
The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more
U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds)2 and their U.S. general partners, sponsors, and managers (Advisers) are not directly subject to the Bank Secrecy Act of 1970...more
7/26/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
FATF ,
Fund Managers ,
Hedge Funds ,
Office of Foreign Assets Control (OFAC) ,
Politically Exposed Person (PEPs) ,
Popular ,
Private Funds ,
Red Flags Rule ,
SDN List ,
Venture Capital
I. Introduction-
U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds),1 and their U.S. general partners, sponsors, and managers (Advisers), are not directly subject to the...more
2/20/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
FinCEN ,
Fund Managers ,
Hedge Funds ,
Investment Adviser ,
Money Laundering Control Act (MLCA) of 1986 ,
Office of Foreign Assets Control (OFAC) ,
Private Funds ,
Securities and Exchange Commission (SEC) ,
Venture Capital