News & Analysis as of

Enforcement Actions Money Services Business

Orrick, Herrington & Sutcliffe LLP

Texas expands its banking commissioner’s powers into money services

On June 20, the governor of Texas signed into law HB 3805, expanding the Texas Department of Banking’s (TDB) enforcement powers over money services businesses. As stated in the state’s bill analysis, the TDB previously had...more

Ballard Spahr LLP

FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

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In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels - UPDATED 3/18/25

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

Ballard Spahr LLP

Brink’s Global Services Faces Major Fines: The DOJ and FinCEN Crackdown on AML Violations

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Brinks Global Services USA (“BGS USA”), a global leader in secure logistics, found itself at the center of a significant regulatory investigation due to its failure to meet anti-money laundering (“AML”) obligations....more

The Volkov Law Group

OFAC Fines U.S. Person $1 Million for Multiple Violations of Sanctions Regime Against Iran

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In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations...more

Harris Beach Murtha PLLC

[Webinar] Third Party Risk is Your Risk - January 24th, 11:00 am - 12:00 pm EST

• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more

Ballard Spahr LLP

Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Multiple Billions – While its Founder, Owner and...

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As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more

Orrick, Herrington & Sutcliffe LLP

Illinois announces new consumer protections for digital assets, proposes new money transmitter licensing provisions

On February 21, the Illinois Department of Financial and Professional Regulation (IDFPR) announced several legislative initiatives to establish consumer protections for cryptocurrencies and other digital assets and provide...more

The Volkov Law Group

OFAC Focuses on Cybercrime by Sanctioning the Hydra Darknet Market and GARANTEX Cryptocurrency Exchange

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Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria.  On April...more

The Volkov Law Group

Payoneer Pays $1.4 Million to Resolve OFAC Sanctions Violations

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Payoneer, Inc., an online money transmitter and prepaid access company, agreed to pay $1.4 million to OFAC to settle violations of multiple sanctions programs.  ...more

McGlinchey Stafford

Scared Of Your Clients’ Involvement With Cryptocurrency?

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Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more

The Volkov Law Group

MoneyGram Payment Systems Agrees to Pay OFAC $34k for Sanctions Violations

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MoneyGram settled with OFAC for $34,329 for 359 sanctions programs violations.  MoneyGram is a global payments service. According to OFAC, the 359 transactions totaled $105,627 in value and were processed on behalf of...more

Pillsbury Winthrop Shaw Pittman LLP

Biden Administration Faces Last-Ditch Efforts by the Trump Administration to Curb the Digital Assets Industry

The incoming Biden team will need to quickly address significant digital asset issues, including a major enforcement action and a significant proposed FinCEN rule initiated in the final days of the outgoing administration. ...more

Polsinelli

Superman29 - Welcome to the Phantom Zone

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In a lesson to everyone that the use of foolish monikers will come back to haunt you, Kais Mohammad, 36, a.k.a. “Superman29,” has met his Kryptonite - the U.S. Department of Justice. ...more

Eversheds Sutherland (US) LLP

Cryptocurrency misappropriation, hacking, theft and fraud on target for banner year

According to one blockchain and cryptocurrency security firm, this year is on pace to be the second highest in cryptocurrency theft, hacking and fraud, with January through May 2020 already seeing $1.36 billion stolen in...more

American Conference Institute (ACI)

[Virtual Forum] Anti-Money Laundering and Financial Crime - July 14th - 15th, 8:00 am - 5:00 pm EDT

Virtually attend the forum to learn how to align your compliance program with the amended Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) regulations effective 2020/2021. In June 2019 amended...more

Ballard Spahr LLP

DOJ Charges Turkish State-Owned Halkbank With Money Laundering, Fraud, and Iran-Related Sanctions Offenses

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Indictment Alleges that Bank and its Officers Used Front Companies to Evade Prohibitions on Iran’s Access to the U.S. Financial System - The U.S. Attorney for the Southern District of New York has charged Turkish state-owned...more

Foodman CPAs & Advisors

If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)

FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more

Jones Day

Financial Crimes Enforcement Network Consolidates Guidance on Virtual Currencies

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The Situation: The Financial Crimes Enforcement Network ("FinCEN") released interpretive guidance concerning the application of the Bank Secrecy Act ("BSA") and the anti-money laundering ("AML") regulations to certain...more

Wilson Sonsini Goodrich & Rosati

Virtual Currency Guidance + Enforcement Actions = AML Regulators Are Watching

A few days before thousands of blockchain industry participants poured into New York for “Blockchain Week,” the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on virtual currencies...more

Sheppard Mullin Richter & Hampton LLP

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

Ballard Spahr LLP

Update: Government Enforcement in the Cryptocurrency Space

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First Post in a Two-Part Series - Recent actions in the crypto realm demonstrate that authorities and regulators have not slackened their commitment to applying and enforcing Anti-Money Laundering (“AML”) laws and...more

Hogan Lovells

You can't spell FinTech without FTC

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The Consumer Financial Protection Bureau (CFPB) is not the only consumer watchdog keeping a close eye on the financial sector and certainly not the only agency focused on FinTech. This is also a key area for the Federal Trade...more

Orrick - On the Chain

FinCEN Shows a Little Bite to Go with Its Bark

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Last week, the Financial Crimes Enforcement Network (FinCEN) backed up its strong public statements about enforcing the anti-money laundering (AML) laws with respect to cryptocurrency by bringing an enforcement action against...more

Fox Rothschild LLP

FinCEN Announces First-Ever Enforcement Action Against Bitcoin Trader For Violations Of BSA

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Last week, the Financial Crimes Enforcement Network (FinCEN) announced its first-ever civil penalty against a cryptocurrency exchanger for willful violations of the Bank Secrecy Act (BSA). According to the FinCEN Assessment...more

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