News & Analysis as of

Anti-Money Laundering SAR FinCEN

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

Orrick, Herrington & Sutcliffe LLP

FinCEN warns financial institutions of surge in mail theft-related check fraud

On February 27, FinCEN issued an alert to financial institutions on the nationwide surge in check fraud schemes targeting the U.S. mail. Mail theft-related check fraud, FinCEN explained, generally relates to the fraudulent...more

Orrick, Herrington & Sutcliffe LLP

FinCEN offers suspicious activity reporting guidance for human smuggling along U.S.- Mexico border

On January 13, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling along the...more

Morrison & Foerster LLP

FinCEN Looks to Regulate the Real Estate Market

Morrison & Foerster LLP on

On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more

Mitchell, Williams, Selig, Gates & Woodyard,...

The High Points: SARs and the Three Tiered Framework for MRBs

As green states continue to grow, intentional or unintentional exposure to Marijuana Related Business (“MRB”) customers for financial institutions and broker-dealers is an inevitability. Whether your business has decided to...more

K&L Gates LLP

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

K&L Gates LLP on

This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

Ballard Spahr LLP

Investment Management Update - October 2015

Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Troutman Pepper

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

Troutman Pepper on

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

Baker Donelson on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

K&L Gates LLP

AML Update: The Rumors Are True – FinCEN Proposes Regulations That Will Require SEC Registered Investment Advisers to Adopt an AML...

K&L Gates LLP on

On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more

The Volkov Law Group

FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers

The Volkov Law Group on

FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...more

Katten Muchin Rosenman LLP

Anti-Money Laundering Program and Suspicious Activity Report Filing for Investment Adviser

The Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would require registered investment advisers to establish anti-money laundering programs and file suspicious activity reports with...more

Katten Muchin Rosenman LLP

FinCEN Proposes New Anti-Money Laundering Rules for Investment Advisers

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury, released proposed rules that would extend anti-money laundering (AML) requirements to investment advisers...more

Stinson - Corporate & Securities Law Blog

FinCEN Proposes Extending Anti-Money Laundering Compliance Requirements to Investment Advisers

On Tuesday, the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would require SEC-registered investment advisers, including private equity and hedge funds, to comply...more

The Volkov Law Group

Rolling the Dice: Casinos, FinCEN and AML Compliance

The Volkov Law Group on

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML...more

McGuireWoods LLP

AML Compliance Developments in the Gaming Industry

McGuireWoods LLP on

Executives of regulated entities often lament that fulfilling compliance obligations interferes with their ability to operate their business. However, an extensive (and extended) regulator investigation with the potential for...more

Holland & Knight LLP

FinCEN Doubles Down on Casinos with Heightened Regulatory Expectations - Casino Managers and Tribal Gaming Commissioners Need to...

Holland & Knight LLP on

For the second time in nine months, Financial Crimes Enforcement Network (FinCEN) Director Jennifer Shasky Calvery has publicly addressed FinCEN's increasing concerns regarding casino compliance with the Bank Secrecy Act...more

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