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Financial Crimes Suspicious Activity Reports (SARs) Financial Institutions

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Lowenstein Sandler LLP

Three Banks Targeted by FinCEN in FEND Off Fentanyl Act Actions: What to Know

Lowenstein Sandler LLP on

On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Gordon Rees Scully Mansukhani

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...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

A&O Shearman

UK Financial Intelligence Unit SARS report published

A&O Shearman on

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

K&L Gates LLP

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

K&L Gates LLP on

On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more

Skadden, Arps, Slate, Meagher & Flom LLP

Europol Published Practical Guide for Cooperation Between Financial Institutions and Investigative Authorities

Public-private partnerships across the world between financial institutions, financial intelligence units and investigative authorities have laid the foundation to advance criminal investigations. However, there is further...more

Bradley Arant Boult Cummings LLP

Community Banks and BSA/AML Compliance: The OCC’s Consent Order with Clear Fork Bank Proves Regulators Aren’t Only Focused on...

On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Lowenstein Sandler LLP

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

Lowenstein Sandler LLP on

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 Reports Check Fraud Amounting to $688 Million Over Six Month Period

Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) issued last month an in-depth report on check fraud stemming from mail theft (“Report”).  This is a pernicious and expanding problem.  The Report follows upon a joint alert...more

Brownstein Hyatt Farber Schreck

Federal and State Regulators Increase Scrutiny of Casino AML Practices

Recent money laundering-related enforcement actions targeting casinos by both the U.S. Department of Justice (“DOJ”) and state regulators suggest increasing scrutiny of anti-money laundering (“AML”) compliance efforts within...more

Jones Day

Investment Advisers Subject to AML and SARs Requirements

Jones Day on

The Situation: The Financial Crimes Enforcement Network ("FinCEN") has adopted a rule that subjects certain investment advisers to anti-money laundering/countering the financing of terrorism program ("AML") requirements...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

K2 Integrity

Pending FinCEN Investment Adviser Rule: Industry Perspective On Next Steps You Should Be Taking

K2 Integrity on

On 22 August 2024, K2 Integrity hosted a webinar discussing considerations related to the pending anti-money laundering rule (AML) for investment advisers (IAs) from the Financial Crimes Enforcement Network (FinCEN). The...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

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The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

Ballard Spahr LLP

BSA Filings and Their Utility to Law Enforcement:  An Industry Viewpoint

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In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more

Ballard Spahr LLP

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

Ballard Spahr LLP on

The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...more

Troutman Pepper Locke

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

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As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Ballard Spahr LLP

BSA Filings and Their Utility to Law Enforcement:  A Guest Blog

Ballard Spahr LLP on

Yesterday we were very pleased to welcome guest blogger, Don Fort, who is the Director of Investigations at Kostelanetz LLP, and the past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division....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

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

Ballard Spahr LLP

FinCEN Issues Reminder to Financial Institutions to Identify and Report Elder Financial Exploitation

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On June 14, 2024, President Biden declared June 15th World Elder Abuse Awareness Day.  In honor of the day, the Financial Crimes Enforcement Network (FinCEN) reminded financial institutions (FIs) to remain vigilant in...more

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