News & Analysis as of

AML/CFT Regulatory Requirements

Goodwin

The Liability of Crypto-Asset Service Providers for Failure to Register With the AMF: Civil Consequences of Regulatory...

Goodwin on

The judgment delivered by the Court of Appeal of Grenoble on 26 June 2025 marks a significant development in the jurisprudence concerning the liability of digital asset service providers (DASPs)....more

ArentFox Schiff

Treasury Postpones Effective Date of Investment Adviser AML Rule

ArentFox Schiff on

On July 21, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a two-year postponement of the Anti-Money Laundering (AML)/Countering the Financing of Terrorism (CFT) Program and...more

Fenwick & West LLP

FinCEN Delays Investment Adviser AML/CFT Rule to January 2028: What Fund Managers Should Know

Fenwick & West LLP on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of its 2024 investment advisor AML rule for registered investment...more

DLA Piper

Blockchain and Digital Assets News and Trends – July 2025

DLA Piper on

This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on

Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Jones Day

Crypto Assets, CASPS, and AML/CFT Compliance: The New European Regulatory Landscape Under MiCA and AMLR

Jones Day on

The rise of crypto assets and decentralized finance has challenged traditional regulatory frameworks, particularly in the area of anti-money laundering and countering the financing of terrorism ("AML/CFT")....more

BCLP

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

BCLP on

FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

Stinson LLP

Payment Stablecoin Regulatory Framework Established as GENIUS Act Signed Into Law

Stinson LLP on

The Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act) was recently signed into law by President Trump, establishing a regulatory framework for payment stablecoins and their issuers. The...more

Alston & Bird

Financial Institutions Permitted to Use Third Parties to Collect Customers’ Taxpayer Identification Numbers for Identity...

Alston & Bird on

Our Financial Services and White Collar, Government & Internal Investigations Teams examine the Financial Crimes Enforcement Network’s new customer identification program (CIP) exemption that allows banks and credit unions to...more

Vedder Price

The GENIUS Act: Stablecoin Regulation Enters the Federal Framework

Vedder Price on

On July 18, 2025, President Trump signed the Guaranteed Essential National Infrastructure for U.S. Act (the “GENIUS Act”) into law, marking the first comprehensive U.S. federal regulatory framework for payment stablecoins. ...more

Jones Day

Direct Supervisory Powers of the New European Anti-Money Laundering Authority

Jones Day on

The European Union Anti-Money Laundering ("AML") package includes Regulation (EU) 2024/1620 of the European Parliament and of the Council of May 31, 2024, establishing the Authority for Anti-Money Laundering and Countering...more

Mayer Brown

Hong Kong’s Stablecoin Bill: Key Amendments and Next Steps Following Legislative Passage

Mayer Brown on

On 21 May 2025, the Hong Kong Legislative Council passed the much-anticipated Stablecoins Bill (“Bill”), now citable as the Stablecoins Ordinance (“Ordinance”), marking a significant milestone in the city’s ambition to become...more

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

Ballard Spahr LLP on

We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

Seward & Kissel LLP

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

Seward & Kissel LLP on

On July 21, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was delaying the effective date of its final rule establishing Anti-Money Laundering/Countering the Financing...more

Eversheds Sutherland (US) LLP

Investment adviser anti-money laundering rule postponed and reopened for further review

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

Morrison & Foerster LLP

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

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

Ropes & Gray LLP

FinCEN Delays AML Program Rule for Investment Advisers

Ropes & Gray LLP on

On July 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it intends to delay implementation of its final rule, Anti-Money Laundering/Countering the Financing of Terrorism...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Establishes First Federal Regulatory Framework for Stablecoins: The GENIUS Act Passes Congress and Awaits President Trump’s...

- What is new: The U.S. Congress has passed the GENIUS Act, establishing the first federal regulatory framework for payment stablecoins, addressing consumer protection, financial stability and AML compliance. - Why it...more

A&O Shearman

ESAs and AMLA sign MoU to strengthen EU AML supervision

A&O Shearman on

The European Supervisory Authorities (the European Banking Authority, European Insurance and Occupational Pensions Authority and European Securities Markets Authority—the ESAs) have announced the signing of a multilateral...more

Robinson Bradshaw

Application of New Anti-Money Laundering Regulations to Advisers to Private Funds

Robinson Bradshaw on

On Sept. 4, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a final rule imposing new anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements on...more

A&O Shearman

FATF publishes targeted update and guidance on virtual assets and VASPs

A&O Shearman on

The Financial Action Task Force (FATF) has published its sixth targeted update on the implementation of its standards for virtual assets (VAs) and virtual asset service providers (VASPs), alongside an updated webpage. The...more

Dorsey & Whitney LLP

Investment Adviser Compliance with FinCEN’s AML/CFT Rule

Dorsey & Whitney LLP on

On August 28, 2024, Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) that imposes comprehensive anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements on...more

A&O Shearman

FATF publishes updated guidance on financial inclusion and AML/CFT measures

A&O Shearman on

The Financial Action Task Force (FATF) has published updated guidance accompanied by a press release, on financial inclusion and anti-money laundering and counter terrorist financing measures (AML/CFT). The update follows the...more

A&O Shearman

FATF report identifies vulnerabilities in counter proliferation financing

A&O Shearman on

The Financial Action Task Force (FATF) has published a report and accompanying press release, highlighting significant vulnerabilities in the global financial system's ability to combat proliferation financing (PF) and...more

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