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Anti-Money Laundering FinCEN

Cadwalader, Wickersham & Taft LLP

New Lessons in Regulation, August 2025 - FinCEN Extends Effectiveness Date of Orders Targeting CIBanco, Intercam, and Vector until...

Parties have an additional six weeks to prepare for the impact of FinCEN’s June 25, 2025 orders targeting three Mexican financial institutions. On August 19, 2025, FinCEN extended the effectiveness date of three orders...more

DLA Piper

Blockchain and Digital Assets News and Trends – August 2025

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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

DLA Piper

Art Market Integrity Act Introduced With Bipartisan Support to Combat Money Laundering Risks in the Art Industry

DLA Piper on

Senate Judiciary Committee Chairman Chuck Grassley (R-IA) and Senator John Fetterman (D-PA) have introduced the Art Market Integrity Act (AMIA) in Congress....more

Hogan Lovells

UPDATE #3: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed again

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Key takeaways U.S. financial institutions that conduct funds transfers with the institutions subject to FinCEN’s Section 2313a orders now have until 20 October 2025 to implement compliance procedures and to stop funds...more

DLA Piper

US Escalates Pressure Against Mexican Cartels

DLA Piper on

The US government announced two major sanctions and related actions against Mexican cartels, first targeting their involvement in timeshare fraud, followed by a broader crackdown on other revenue sources the next day....more

Mayer Brown

FATF Revises AML Standards For Certain Funds Transfers

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On June 18, 2025, the Financial Action Task Force (“FATF”) revised the Travel Rule requirements for certain funds transfers (the “2025 Revisions”). The 2025 Revisions are intended to adapt anti-money laundering (“AML”)...more

Ankura

Toothless: How Proposed Changes to the Corporate Transparency Act Diminish its Efficacy

Ankura on

17 Back in 2021, the U.S. Government passed the Corporate Transparency Act (CTA), which was an effort to improve upon the Bank Secrecy Act (BSA) and bolster the nation’s defenses against Money Laundering and Terrorist...more

Lowndes

From Cash to Crypto: Could USD Stablecoins Be the High Road for Florida’s Cannabis Industry

Lowndes on

Why Are Florida’s Cannabis Businesses Still Stuck in the Cash Age? In Florida, licensed medical marijuana businesses may be legal under state law, but under federal law cannabis remains a Schedule I controlled substance....more

Mayer Brown

The Tornado Cash Trial’s Mixed Verdict: Implications for Developer Liability

Mayer Brown on

On August 6, 2025, following a four-week trial, a jury in the Southern District of New York delivered a mixed verdict in the criminal case against Tornado Cash co-founder Roman Storm. The jury convicted Storm of conspiring to...more

Patomak Global Partners

FinCEN Targets Three Mexican Financial Institutions for Fentanyl Trafficking

The Trump Administration has repeatedly signaled its prioritization of targeting traffickers of synthetic opioids, especially fentanyl. On January 20, 2025, President Trump signed an Executive Order “creating a process by...more

Vedder Price

FinCEN Postpones Effective Date of Investment Adviser Anti-Money Laundering Requirements

Vedder Price on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone by two years the effective date of the final rule that it adopted on August 28, 2024...more

Adams & Reese

FinCEN Rule Targets All-Cash Residential Real Estate Deals Involving Entities & Trusts

Adams & Reese on

A new nationwide anti-money laundering rule introduces mandatory reporting to the U.S. Department of Treasury’s FinCEN (Financial Crimes Enforcement Network) for specific all-cash residential real estate transactions...more

Orrick, Herrington & Sutcliffe LLP

FDIC Approves Use of Pre-Populated Customer Information During Account Opening

On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more

Perkins Coie

FinCEN Addresses Increased Fraud Involving Convertible Virtual Currency Kiosks

Perkins Coie on

Key Takeaways - - The Financial Crimes Enforcement Network’s recently issued notice, which addresses regulations and increased rates of fraud surrounding convertible virtual currency kiosks, carries significant implications...more

Orrick, Herrington & Sutcliffe LLP

Fed joins agencies in allowing banks to access tax ID numbers from third parties

On July 31, the Fed, with the concurrence of FinCEN, issued an order exempting banks supervised by the Fed from a Customer Identification Program (CIP) rule implementing Section 326 of the USA PATRIOT Act. As previously...more

King & Spalding

Fed Follows Earlier OCC, FDIC, and NCUA Orders Allowing Banks to Collect TIN Information from Third Parties

King & Spalding on

On July 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exemptive order in coordination with the Board of Governors of the Federal Reserve System (the “Fed”) that allows...more

Sheppard Mullin Richter & Hampton LLP

FinCEN Warns Financial Institutions of Illicit Activity at Crypto Kiosks

On August 4, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice warning financial institutions about escalating illicit activity involving convertible virtual currency (CVC) kiosks. The notice cites...more

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - August 2025

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Issues Order Delaying Effective Date of Investment Adviser Rule

Following an earlier announcement on July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), on August 5, 2025, issued an Exemptive Relief Order (“Order”) to delay for two years,...more

Ballard Spahr LLP

FDIC clarifies that CIP Rule does not preclude using pre-populated customer information

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On August 5, 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL-39-2025 to state that an FDIC-supervised institution can use pre-populated customer information to satisfy the requirements of the Customer...more

Ballard Spahr LLP

U.S. Senate introduces Act to apply AML/BSA laws to art dealers and auction houses

Ballard Spahr LLP on

On July 23, 2025, Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Bill Cassidy (R-LA), Andy Kim (D-NJ), and David McCormick (R-PA), introduced the federal Art Market Integrity Act (the...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – August 2025

Troutman Pepper Locke on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Buchalter

New Federal Regulatory Regime Provides Foundation for Financial Institutions to be Stablecoin Issuers and Accept Cryptocurrency...

Buchalter on

There has been a flurry of activity in Congress and the White House to liberalize and encourage the development of cryptocurrency as a payment method, including creating a legal regime for depository and non-depository...more

Orrick, Herrington & Sutcliffe LLP

FinCEN delays compliance with investment adviser rule by two years

On July 21, FinCEN announced its intention to postpone the effective date of a final rule which would establish certain anti-money laundering requirements for investment advisers from January 1, 2026, to January 1, 2028. By...more

McGuireWoods LLP

FinCEN Hits Pause: AML Rule for Investment Advisers Delayed

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In a move to balance regulatory efficiency and cost, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) officially announced on July 21, 2025, that it will postpone the effective date, from...more

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