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Bank Secrecy Act › FinCEN › Financial Institutions

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
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

Sheppard Mullin Richter & Hampton LLP

FinCEN Warns Financial Institutions of Illicit Activity at Crypto Kiosks

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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

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

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Bradley Arant Boult Cummings LLP on

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

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On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Lowenstein Sandler LLP

Three Banks Targeted by FinCEN in FEND Off Fentanyl Act Actions: What to Know

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On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more

Troutman Pepper Locke

Federal Agencies Issue Order Granting Exemption for Financial Institutions on TIN Collection

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The Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) (collectively, the agencies), with concurrence from the...more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

Ballard Spahr LLP

Anti-Money Laundering Aspects of the GENIUS Act

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On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking,...more

K&L Gates LLP

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

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On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more

The Volkov Law Group

Mitigating Risks of “Interacting” with Cartels and TCOs

The Volkov Law Group on

We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs).  Companies need to understand the laws used to...more

Ballard Spahr LLP

Patriot Bank Enters Agreement with OCC to Address Regulatory Concerns

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On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more

Oberheiden P.C.

10 Keys to Conducting an Effective AML/BSA Audit in 2025

Oberheiden P.C. on

Financial institutions need to remain vigilant about managing anti-money laundering and Bank Secrecy Act (AML/BSA) compliance in 2025. As the financial ecosystem becomes increasingly complex, and as transactions increasingly...more

Troutman Pepper Locke

FDIC Acting Chairman Hill Supports Modernizing Customer Identification Program Requirements

Troutman Pepper Locke on

In a recent letter to Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill expressed his support for updating the Customer...more

K2 Integrity

Fiat Ramps Unlocked: Practical Tips For Banks And Crypto Firms

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Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more

Morrison & Foerster LLP

FinCEN Asks: Are Your Customers Deepfaking It?

Morrison & Foerster LLP on

“Can you create a New York driver’s license for a John Brown with brown hair and brown eyes, 5’11”, 200 lbs, living at 123 State Street in New York? Also, a bank statement from XYZ Bank displaying $235,887 in the account,...more

Bradley Arant Boult Cummings LLP

$3B TD Bank AML Settlement Is A Wake-Up Call For All Banks

Bradley Arant Boult Cummings LLP on

On Oct. 10, Attorney General Merrick Garland announced that TD Bank pled guilty to conspiracy to commit money laundering and agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice's...more

Davis Wright Tremaine LLP

FinCEN Warns of Criminal Use of Deepfake Technology to Circumvent Controls

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Generative artificial intelligence (AI) holds tremendous promise for financial institutions and their customers. But that promise comes with potential peril, as highlighted in a recent alert issued by the U.S. Treasury...more

Foodman CPAs & Advisors

TD Bank gets $1.3 Billion Penalty from FinCEN

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On 10/10/24, FinCEN assessed a record $1.3 billion penalty against TD Bank for BSA violations. This unprecedented penalty should function as a cautionary message and a warning to all financial institutions. All financial...more

ArentFox Schiff

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

ArentFox Schiff on

On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Ballard Spahr LLP

Bank Policy Institute Critiques Notice of Proposed Rulemaking to Modernize AML/CFT Programs

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The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of...more

Bradley Arant Boult Cummings LLP

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

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On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

The Volkov Law Group

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements  (Part III of IV)

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TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...more

Foodman CPAs & Advisors

Mail Theft-Check Fraud

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Back on February 27, 2023, FinCEN issued (in close collaboration with the United States Postal Inspection Service) an Alert on Nationwide Surge in Mail Theft-Related Check Fraud Schemes Targeting the U.S. Mail....more

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