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Bank Secrecy Act › Regulatory Requirements › Anti-Money Laundering

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 -
Orrick, Herrington & Sutcliffe LLP

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

Orrick, Herrington & Sutcliffe LLP on

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

Adler Pollock & Sheehan P.C.

The GENIUS Act of 2025: The First Federal Legislation for the Regulation of Payment Stablecoins

Adler Pollock & Sheehan P.C. on

On July 18, 2025, the Guiding and Establishing National Innovations for U.S. Stablecoins Act (the “GENIUS Act”) was signed into law by President Trump. The GENIUS Act is the first federal legislation regulating cryptocurrency...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

Morrison & Foerster LLP

Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One)

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On July 14, 2025, the federal banking agencies issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”)....more

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Proskauer Rose LLP

Treasury to Delay Investment Adviser AML Rule to 2028, Announces Intent to Reconsider AML and CIP Rules

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On July 21, 2025, the Department of the Treasury announced a two-year postponement of the much-anticipated anti-money laundering (AML) rule, adopted by Treasury’s Financial Crimes Enforcement Network (FinCEN) in 2024,...more

Cooley LLP

FinCEN to Postpone Investment Adviser Anti-Money Laundering Rule

Cooley LLP on

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to (1) postpone until January 1, 2028, the effective date of the final anti-money laundering rule...more

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...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

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

Brownstein Hyatt Farber Schreck

Recent Enforcement Actions a Reminder of the Importance of BSA Compliance for Nevada Casinos

Brownstein Hyatt Farber Schreck on

Following a multiyear lull, the Nevada gaming industry has recently experienced a flurry of federal and state regulatory actions related to the enforcement of the Bank Secrecy Act. Just the past several months alone have seen...more

Mayer Brown

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

Mayer Brown on

On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

Ballard Spahr LLP

Anti-Money Laundering Aspects of the GENIUS Act

Ballard Spahr LLP on

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

Jones Day

Updates on Proposed Stablecoin Legislation: the GENIUS Act and the STABLE Act

Jones Day on

As Congress moves to enact comprehensive stablecoin legislation under the Trump administration, both the Senate and the House of Representatives have updated their respective payment stablecoin bills. Our recent Commentary...more

Alston & Bird

FinCEN Issues Geographic Targeting Order for U.S. Southwestern Border

Alston & Bird on

Our Financial Services and White Collar, Government & Internal Investigations Groups unpack the Financial Crimes Enforcement Network’s new geographic targeting order aimed at combatting money laundering and other illegal...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

Carlton Fields

Deadline Approaches for RIAs to Adopt AML Programs CIP Requirements Remain in Limbo

Carlton Fields on

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). For...more

Eversheds Sutherland (US) LLP

Dual Registrant Regulatory Roundup - January 2025

Eversheds Sutherland (US) LLP on

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

Paul Hastings LLP

State-Level Developments: The Regulatory Landscape for Digital Assets

Paul Hastings LLP on

As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more

Troutman Pepper Locke

Treasury Department Releases Semiannual Regulatory Agenda

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On August 16, the U.S. Department of the Treasury published its semiannual regulatory agenda in the Federal Register, detailing the agency’s upcoming regulatory actions and priorities. The agenda outlines the proposed, final,...more

Jenner & Block

FinTech Focus: Investment Advisers Join Ranks of Financial Institutions Subject to the Bank Secrecy Act

Jenner & Block on

Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

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The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

K2 Integrity

[Webinar] AML/CFT Rules for Investment Advisers - June 12th, 9:30 am PT

K2 Integrity on

On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

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