News & Analysis as of

Executive Orders › BSA/AML

Morgan Lewis

Financial Institutions Face Investigations and Possible Referral to DOJ Based on Past ‘Debanking’ Practices

Morgan Lewis on

An executive order signed by the US president on August 7, 2025, titled Guaranteeing Fair Banking for All Americans, seeks to prohibit financial institutions from engaging in “debanking” practices, such as denying services or...more

Holland & Knight LLP

FinCEN Geographic Targeting Order Imposes Additional Recordkeeping and Reporting Requirements

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

Troutman Pepper Locke on

On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...more

McGlinchey Stafford

Cryptocurrency’s impact on BSA/AML and Sanctions programs

McGlinchey Stafford on

The market for digital assets has exploded in recent years. Digital and virtual currency activities provide great opportunities financially and technologically. However, such currencies can be utilized for illicit activity...more

Dorsey & Whitney LLP

Crypto Assets: From Off The Grid To A Seat At The Table

Dorsey & Whitney LLP on

The Beginning - Crypto assets were initially “off the grid,” and many early proponents celebrated the promise of their regulatory independence. While conventional assets were governed by a virtual alphabet soup of federal...more

Dorsey & Whitney LLP

FinCEN Urges Financial Institutions to Guard Against Attempts to Evade Sanctions

Dorsey & Whitney LLP on

On March 7, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “FinCEN Alert”) urging financial institutions to proactively guard against possible attempts to evade recently implemented sanctions...more

Perkins Coie

Fintech Legal Report - July 2021

Perkins Coie on

President Biden Issues an Executive Order on Competition with Implications for Financial Institutions - On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. The...more

Hogan Lovells

EO prohibits U.S. persons from engaging in certain transactions involving eight Chinese apps

Hogan Lovells on

On 5 January 2021, President Donald Trump issued Executive Order (EO) 13971 on "Addressing the Threat Posed By Applications and Other Software Developed or Controlled By Chinese Companies," which prohibits U.S. persons from...more

Ballard Spahr LLP

U.S. Bans Venezuela’s Oil-Backed Virtual Currency, “Petro,” and Announces Plans to Publish SDNs’ Virtual Currency Addresses

Ballard Spahr LLP on

Last week, President Donald Trump issued an Executive Order banning “all transactions” and “dealings” by any individual or entity in the United States that involve “any digital currency, digital coin, or digital token” issued...more

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