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Financial Crimes Reporting Requirements

Ankura

Toothless: How Proposed Changes to the Corporate Transparency Act Diminish its Efficacy

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17 Back in 2021, the U.S. Government passed the Corporate Transparency Act (CTA), which was an effort to improve upon the Bank Secrecy Act (BSA) and bolster the nation’s defenses against Money Laundering and Terrorist...more

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

K&L Gates LLP

Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

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On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more

Troutman Pepper Locke

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Ropes & Gray LLP

FinCEN Delays AML Program Rule for Investment Advisers

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On July 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it intends to delay implementation of its final rule, Anti-Money Laundering/Countering the Financing of Terrorism...more

Friling Law

Legal Guidance for Financial Integrity and Whistleblower Protection

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Over the past few years, whistleblowers have become a driving force in uncovering financial misconduct in the U.S. Individuals may report illicit financial activity, including money laundering, sanctions evasion, fraud, and...more

WilmerHale

DOJ Antitrust Announces New Whistleblower Program

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On July 8, 2025, the Department of Justice, Antitrust Division (“Antitrust Division”) announced that it is creating the Antitrust Whistleblower Rewards Program (the “Whistleblower Program”) in partnership with the U.S. Postal...more

Hogan Lovells

Reform of Mexico's Anti-Money Laundering Law: New measures to combat transactions with funds of illicit origin

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Changes to concepts including Compliance Officer and Controlling Beneficiary of the Federal Law for the Prevention and Identification of Operations with Illicit Resources (by its acronym in Spanish – LFPIORPI) also known as...more

Morrison & Foerster LLP

Show Them the Money: New Rewards Program Heightens Incentives for Antitrust Whistleblowers

On July 8, 2025, the Department of Justice Antitrust Division (the Division) announced a new program that could provide monetary payouts to individuals who report criminal antitrust violations. The program, described in a...more

Phelps Dunbar

DOJ Expands Whistleblower Rewards to Include Immigration Violations

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Since May 12, when the U.S. Department of Justice (DOJ) announced policy changes to the Corporate Whistleblower Awards Pilot Program (CWAP), employers now face increased scrutiny and potential risks due to the DOJ’s recent...more

ArentFox Schiff

DOJ’s Antitrust Division Launches First-Ever Whistleblower Awards Program

ArentFox Schiff on

On July 8, the US Department of Justice’s (DOJ) Antitrust Division, in partnership with the United States Postal Service (USPS), announced the launch of a Whistleblower Rewards Program. This new initiative is designed to...more

A&O Shearman

FATF report identifies vulnerabilities in counter proliferation financing

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The Financial Action Task Force (FATF) has published a report and accompanying press release, highlighting significant vulnerabilities in the global financial system's ability to combat proliferation financing (PF) and...more

Holland & Knight LLP

CFPB Provides Guidance on Referrals for Potential Criminal Enforcement

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The CFPB has issued a policy statement describing its plan to address criminally liable regulatory offenses. President Donald Trump previously issued an executive order on May 9, 2025, requiring each federal agency to publish...more

Troutman Pepper Locke

In Response to the President’s Directive, CFPB Unveils New Strategy to Tackle Criminal Regulatory Offenses

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Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in...more

McDermott Will & Schulte

Anzeigen digital – BaFin ermöglicht zukünftig digitale Anzeigen zu Geldwäschebeauftragten

Die Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) öffnet ihr Portal der Melde- und Veröffentlichungsplattform (MVP-Portal) zukünftig auch für geldwäscherechtliche Anzeigen. Konkret betrifft dies alle im Voraus...more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

Orrick, Herrington & Sutcliffe LLP

Senators pen bipartisan letter arguing rescission of Treasury rule

On May 27, Sens. Sheldon Whitehouse (D-RI) and Charles Grassley (R-IA) wrote to the Treasury encouraging recission of the interim final rule requiring “foreign reporting companies,” but not domestic entities or U.S. citizens,...more

K&L Gates LLP

Key Compliance Tips on How to Respond to Information Requests From OFSI

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On 8 May 2025, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of HM Treasury published a penalty notice regarding a breach of financial sanctions by a UK registered company—Svarog Shipping & Trading...more

Conyers

Country Update - Bermuda: AML

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Bermuda is a leading international financial centre and maintains a comprehensive body of primary legislation relating to money laundering and terrorist financing, supported by a range of general and sector specific guidance...more

Oberheiden P.C.

10 Important Facts About FinCEN’s Whistleblower Program

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The Financial Crimes Enforcement Network (FinCEN) is one of a handful of federal authorities that have adopted whistleblower programs focused on facilitating enforcement in hard-to-target areas. While FinCEN focuses its...more

Morrison & Foerster LLP

CFTC Advisory Outlines Materiality Criteria for Enforcement Referrals

On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more

Greenberg Glusker LLP

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

Mayer Brown

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

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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

Hogan Lovells

Changes in Beneficial Ownership rules under the new EU Anti-Money Laundering Regulation (EU) 2024/1624

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The adoption of the EU Anti Money Laundering Regulation (EU) 2024/1624 (the “AML Regulation") marks a significant advancement in the European Union's efforts to combat money laundering and terrorist financing. Effective from...more

A&O Shearman

UK Financial Intelligence Unit SARS report published

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The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...more

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