News & Analysis as of

Anti-Money Laundering FinCEN AML/CFT

Ballard Spahr LLP

FinCEN’s Focus on Cryptocurrency Kiosks and Financial Crime

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On August 4, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice FIN-2025-NTC1 (the “Notice”) to address mounting concerns over regulatory risks related to convertible virtual currency (“CVC”) kiosks, also...more

Troutman Pepper Locke

Treasury Issues Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets

Troutman Pepper Locke on

On August 18, the U.S. Department of the Treasury issued a Request for Comment, inviting interested members of the public to provide input on innovative methods to detect and mitigate illicit finance risks involving digital...more

DLA Piper

Blockchain and Digital Assets News and Trends – August 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

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

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

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

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

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

ArentFox Schiff

Treasury Postpones Effective Date of Investment Adviser AML Rule

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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

Goodwin

FinCEN to Postpone Effective Date and Reopen Anti-Money Laundering Rule for Investment Advisers

Goodwin on

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

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

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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

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

K2 Integrity

Risks Increase As U.S. Escalates Pressure Against Mexico With Regulatory Focus On The Financing Of Fentanyl

K2 Integrity on

The evolving U.S.-Mexico geopolitical relationship is now fundamentally burdened by the growing regulatory, enforcement, and real risks tied to cartel activity, drug trafficking and the fentanyl trade, immigration, and a...more

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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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

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

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

Lowenstein Sandler LLP

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

Lowenstein Sandler LLP on

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

Procopio, Cory, Hargreaves & Savitch LLP

Understanding FinCEN’s New AML/CFT Rule for Investment Advisers

What You Need to Know Before January 1, 2026 - Certain registered investment advisers (RIAs) and Exempt Reporting Advisors (ERAs) will face new federal compliance and filing requirements in the new year. Starting January 1,...more

Mayer Brown

Credibly Challenged Podcast: Interview with Ross Delston, Financial Crime Compliance Expert and Former FDIC Attorney

Mayer Brown on

Matt Bisanz interviews Ross Delston, a financial crime compliance expert and former FDIC attorney. They discuss his views on the trends we should expect to see in financial crimefighting and AML compliance over the next few...more

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