News & Analysis as of

Banking Sector FinCEN

Cadwalader, Wickersham & Taft LLP

FFFrictions, August 2025 - FinCEN Restrictions on Certain Mexican Banks

New and significant prohibitions against financial transactions between U.S. financial institutions and three Mexican financial institutions are set to go into effect in a little over a month on September 4, 2025. In late...more

Lowenstein Sandler LLP

[Webinar] Targeted: How FinCEN's Fentanyl Fight Is Reshaping U.S.–Mexico Financial Compliance - August 7th, 11:00 am - 12:00 pm ET

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Join Lowenstein Sandler and Santamarina + Steta for a timely webinar exploring the legal and compliance implications of recent U.S. Treasury actions under the FEND Off Fentanyl Act. The session, featuring Lowenstein's Robert...more

Hogan Lovells

UPDATE #2: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed until September 4

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U.S. financial institutions that conduct funds transfers with the designated Mexican institutions have until 4 September to implement compliance procedures. Transfers of funds involving these designated Mexican institutions...more

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

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

Bradley Arant Boult Cummings LLP

FinCEN’s Groundbreaking 2313a Orders: What U.S. Banks Need to Know About the Crackdown on Mexican Cartel-Linked Financial...

In a historic move that signals a new era in the fight against illicit opioid trafficking and money laundering, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued its first-ever...more

Hogan Lovells

UPDATE: Effective date regarding FinCEN’s new Section 2313a Orders against three Mexican financial institutions

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U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions have until 21 July to implement compliance procedures. Transfers of funds involving these designated Mexican...more

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2025

The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...more

Hogan Lovells

FinCEN invokes new Section 2313a authority against three Mexican financial institutions: The who, what, when, where, why, and...

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The orders represent the first use of new authorities by FinCEN. U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions will be subject to significant compliance obligations,...more

K2 Integrity

Sanctions Relief For Syria: The United States And European Union Offer Broad Sanctions Relief To Syria

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Building on the Quick Take Alert K2 Integrity published on 15 May 2025, this alert outlines the recent developments regarding the easing of Syria sanctions. While the United States has not fully lifted its Syria sanctions, it...more

Cadwalader, Wickersham & Taft LLP

Rules in Motion, May 2025 - U.S. Issues Broad Sanctions Relief for Syria

On May 23, 2025, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25, which provides broad authorization for U.S. persons to engage in dealings prohibited under the Syrian Sanctions...more

Mayer Brown

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

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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

Orrick, Herrington & Sutcliffe LLP

FDIC Acting Chairman Hill supports flexibility for customer identification program requirements

On February 7, the FDIC’s Acting Chairman Travis Hill released a letter to FinCEN Director Andrea Gacki conveying support for updates to the Customer Identification Program requirements to align with modern practices. ...more

Harris Beach Murtha PLLC

NY Office of Cannabis Management Launches Banking Directory to Support Cannabis Businesses

The New York State Office of Cannabis Management (“OCM”) recently announced it has created a Cannabis Banking Directory (the “Directory”), which currently lists 10 financial institutions servicing cannabis businesses and open...more

Paul Hastings LLP

State-Level Developments: The Regulatory Landscape for Digital Assets

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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

Wilson Sonsini Goodrich & Rosati

Focus on Fintech – Q3 2024

In this issue of Wilson Sonsini's Focus on Fintech, our attorneys discuss updates and developments from federal regulators, including those related to bank-fintech partnerships, cryptocurrency and virtual currency updates,...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2024

The CFPB has adopted a final rule to extend its oversight to the largest nonbank providers of digital consumer payment applications, including those that enable transfers from deposit accounts held at banks and other insured...more

Bradley Arant Boult Cummings LLP

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

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

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

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Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

Paul Hastings LLP

Daily Financial Regulation Update -- Thursday September 5

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September 4, 2024- The Federal Reserve Bank of New York published a Liberty Street Economics blog post entitled “AI and the Labor Market: Will Firms Hire, Fire, or Retrain?” September 4, 2024- The Bank Policy Institute...more

Paul Hastings LLP

Daily Financial Regulation Update -- Friday August 9

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August 8, 2024- The Federal Reserve and U.S. Treasury did not intervene in foreign exchange markets during the April – June 2024 quarter, the Federal Reserve Bank of New York said in its quarterly report to the U.S....more

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Proposes Changes to Anti-Money Laundering Program Requirements for Financial Institutions: 5 Things to Know

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule to counter money laundering and the financing of terrorism that would add significant compliance requirements for financial...more

Cranfill Sumner LLP

FinCEN Is Engaged in Rulemaking to Modernize Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) Programs;...

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On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules to modernize and improve financial institutions’ anti-money laundering and countering the financing...more

Mayer Brown

FinCEN Proposes Rule Reinforcing Financial Institutions’ Duty to Design and Maintain Risk-Based AML/CFT Programs

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On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more

Cadwalader, Wickersham & Taft LLP

FinCEN and Federal Banking Agencies Propose Amendments to Anti-Money Laundering Rules

On June 28, 2024, The U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (the “Proposed Rule”) that would amend FinCEN’s anti-money laundering (“AML”) program rules for...more

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