On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date for certain investment advisers to implement anti-money...more
7/24/2025
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Investment Management ,
Regulatory Requirements ,
Rulemaking Process ,
Suspicious Activity Reports (SARs)
The final judicial barrier to the Financial Crimes Enforcement Network’s enforcement of the Corporate Transparency Act’s beneficial ownership information (BOI) reporting requirements has been lifted.
The Corporate...more
On February 5, 2025, the US Department of Justice (DOJ) issued two memoranda, General Policy Regarding Charging, Plea Negotiations, and Sentencing and Total Elimination of Cartels and Transnational Criminal Organizations,...more
2/10/2025
/ Anti-Bribery ,
Anti-Money Laundering ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Priorities ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Immigration Enforcement ,
Immigration Reform ,
National Security ,
Trump Administration
Certain companies will soon have to give the Financial Crimes Enforcement Network (FinCEN) a look behind the corporate veil. In December 2021, FinCEN issued a Notice of Proposed Rulemaking (NPRM) seeking comment on one...more
On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more
3/21/2022
/ Anti-Money Laundering ,
Compliance ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Russia ,
Terrorist Financing Regulations ,
Virtual Currency
On February 4, 2022, the US Department of the Treasury (the Treasury) released the “Study of the Facilitation of Money Laundering and Terror Finance through the Trade in Works of Art” (the Report). The Report examines the...more
2/18/2022
/ Anti-Money Laundering ,
Art Dealers ,
Bank Secrecy Act ,
Blockchain ,
BSA/AML ,
Compliance ,
Financial Institutions ,
FinCEN ,
Fine Art ,
Non-Fungible Tokens (NFTs) ,
Popular ,
U.S. Treasury
On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) provided an update on implementation of the Anti-Money Laundering Act of 2020 (AML Act) and issued the first government-wide priorities for anti-money...more
7/9/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Biden Administration ,
Corporate Transparency Act ,
Cyber Crimes ,
Cybersecurity ,
Enforcement Priorities ,
Financial Institutions ,
FinCEN ,
Suspicious Activity Reports (SARs)
The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has published an Advance Notice of Proposed Rulemaking (the Proposed Rule) seeking input from the public on the implementation of a reporting...more
On January 1, 2021, the US Senate voted to override President Donald Trump’s veto of H.R. 6395, the National Defense Authorization Act for Fiscal Year 2021 (NDAA). As part of the NDAA, the Anti-Money Laundering Act of 2020...more
1/8/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Congressional Override ,
Financial Institutions ,
FinCEN ,
Foreign Banks ,
NDAA ,
Patriot Act ,
Presidential Veto ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
Transparency ,
Whistleblower Protection Policies
The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more
1/20/2020
/ Annual Reports ,
Anti-Money Laundering ,
Banks ,
BSA/AML ,
Chief Compliance Officers ,
Compliance ,
CSBS ,
Examination Priorities ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Interpretive Opinions ,
Joint Statements ,
OCC ,
Risk Assessment ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
Technology ,
Terrorism Funding