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King & Spalding

Fed Follows Earlier OCC, FDIC, and NCUA Orders Allowing Banks to Collect TIN Information from Third Parties

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On July 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exemptive order in coordination with the Board of Governors of the Federal Reserve System (the “Fed”) that allows...more

McGlinchey Stafford

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

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In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...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

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

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On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Ballard Spahr LLP

FinCEN Withdraws Designation of ABLV Bank as Foreign Financial Institution “Of Primary Money Laundering Concern”

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A Gesture Providing Limited Solace to a Now-Defunct Bank - Six years ago, in early 2018, we blogged about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (“FinCEN’s”) designation of ABLV Bank, AS...more

McGlinchey Stafford

What Would Cannabis Rescheduling Mean for Lending and Payments Legality?

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The U.S. Drug Enforcement Agency’s proposal to reschedule cannabis from a Schedule I to a Schedule III drug under the Controlled Substances Act (CSA) has generated considerable buzz across business sectors, including for the...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

K&L Gates LLP

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

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Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

McCarter & English, LLP

DEA’s Plan to Reschedule Cannabis: Implications and Insights

Earlier this week, the Department of Justice proposed reclassifying cannabis from Schedule I to Schedule III under the Controlled Substances Act. The move follows an August 2023 recommendation from the Department of Health...more

Barnea Jaffa Lande & Co.

Risk to Israeli Entities Posed by International Sanctions – What Is the Exposure and What Are the Dangers?

The executive order signed by United States President Joseph Biden in February 2024 states that the violence being committed by Israeli settlers has reached intolerable levels; poses a serious threat to peace, security, and...more

Moore & Van Allen PLLC

Banks – What Should You Know? Civil Liability for Failure to Detect Human Trafficking

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In 2020, we wrote about the increased regulatory attention on financial institutions’ obligations to detect and respond to human trafficking. In 2021, we wrote about how anti-human trafficking programs fit squarely in banks’...more

Ballard Spahr LLP

OCC Highlights Risks Associated with Compliance Staffing Concerns, Russia Sanctions, Environmental Crimes, Cyber Attacks and...

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On June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022. In the SRP, the OCC opines on its current safety and soundness concerns for banks under...more

Ballard Spahr LLP

Real Estate and Money Laundering: FinCEN Issues Advanced Notice of Regulations for the Real Estate Industry

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On December 6, FinCEN announced that it was issuing an Advanced Notice of Proposed Rulemaking (“AMPRM”) to solicit public comment on potential requirements under the Bank Secrecy Act (“BSA”) for certain persons involved in...more

BakerHostetler

Blockchain and Crypto Initiatives Launch in Foreign Markets, Guidance Issued on Ransomware and Crypto Derivatives, DOJ Indictment...

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Crypto Initiatives Launched by Foreign Banks, Exchanges, Apps, Gaming Firms - According to a press release this week, the “Bank of Thailand (BOT) … has successfully launched the world’s first blockchain-based platform for...more

K&L Gates LLP

OCC Confirms National Banks Can Hold (Certain) Stablecoin Reserves

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On 21 September, the Office of the Comptroller of the Currency (OCC) issued Interpretive Letter Number 11721 (Letter) confirming that national banks and federal savings associations (collectively, national banks) can hold...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2019)

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This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more

Pillsbury - Internet & Social Media Law Blog

Artificial Intelligence and Money Laundering: Would AI Catch Marty Byrde?

In the popular Netflix series Ozark, money launderer Marty Byrde expends a lot of time and energy mitigating the risks that relate to his work, including his drug cartel client, a pair of farmers, the local pastor, and his...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Releases Advisory for Banks, MSBs on Potentially Illicit Transactions with Iran

• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran. • The advisory describes how Iran attempts to access the international...more

BakerHostetler

Blockchain Developments: NY AG Issues Report, Major Japanese Exchange Hacked, Global Attitudes Diverge and Use Cases for Social...

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New York Attorney General Issues Virtual Markets Integrity Initiative Report - On Sept. 18, 2018, the New York Attorney General’s Office released its Virtual Markets Integrity Initiative Report. The report addressed 10 major...more

Perkins Coie

Blockchain Week in Review - June 2017 #5

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Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more

Perkins Coie

Blockchain and the Law - Overview of token sales and bitcoin property rights

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On March 29, 2017, Perkins Coie partner Dax Hansen and associate Josh Boehm were invited to the Cyber Initiative at Stanford Law School to deliver a presentation on several cutting-edge legal issues relating to blockchain...more

Ballard Spahr LLP

2016 Year in Review: Money Laundering (Part One)

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2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

Skadden, Arps, Slate, Meagher & Flom LLP

"FinCEN Finalizes Customer Due Diligence Rule Amid Other Actions to Enhance Financial Transparency"

In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more

Blank Rome LLP

FinCEN Issues Geographic Targeting Order Focused on Money Laundering in L.A.’s Fashion District

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In the latest development in a probe by U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations (HSI) targeting alleged money laundering activities in Los Angeles’ garment trade, the Financial Crimes...more

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