News & Analysis as of

Financial Institutions FinCEN

Cadwalader, Wickersham & Taft LLP

New Lessons in Regulation, August 2025 - FinCEN Extends Effectiveness Date of Orders Targeting CIBanco, Intercam, and Vector until...

Parties have an additional six weeks to prepare for the impact of FinCEN’s June 25, 2025 orders targeting three Mexican financial institutions. On August 19, 2025, FinCEN extended the effectiveness date of three orders...more

Hogan Lovells

UPDATE #3: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed again

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Key takeaways U.S. financial institutions that conduct funds transfers with the institutions subject to FinCEN’s Section 2313a orders now have until 20 October 2025 to implement compliance procedures and to stop funds...more

Sheppard Mullin Richter & Hampton LLP

FinCEN Warns Financial Institutions of Illicit Activity at Crypto Kiosks

On August 4, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice warning financial institutions about escalating illicit activity involving convertible virtual currency (CVC) kiosks. The notice cites...more

Ballard Spahr LLP

FDIC clarifies that CIP Rule does not preclude using pre-populated customer information

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On August 5, 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL-39-2025 to state that an FDIC-supervised institution can use pre-populated customer information to satisfy the requirements of the Customer...more

Buchalter

New Federal Regulatory Regime Provides Foundation for Financial Institutions to be Stablecoin Issuers and Accept Cryptocurrency...

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There has been a flurry of activity in Congress and the White House to liberalize and encourage the development of cryptocurrency as a payment method, including creating a legal regime for depository and non-depository...more

Cadwalader, Wickersham & Taft LLP

FFFrictions, August 2025 - FinCEN Restrictions on Certain Mexican Banks

New and significant prohibitions against financial transactions between U.S. financial institutions and three Mexican financial institutions are set to go into effect in a little over a month on September 4, 2025. In late...more

Foley & Lardner LLP

U.S. FinCEN's Order Targeting CIBanco Will Upend Mexican Fiduciary Market

Foley & Lardner LLP on

In late June 2025, the U.S. Treasury’s FinCEN (Financial Crimes Enforcement Network), under new authorities granted pursuant to the Fentanyl Sanctions Act, the FEND Off Fentanyl Act, and in line with President Trump’s...more

Foley & Lardner LLP

Key Measures for Mexican Entities to Prevent FinCEN Scrutiny

Foley & Lardner LLP on

The recent Orders issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on June 25, 2025, designating CIBanco, Intercam, and Vector as institutions of primary money laundering concern,...more

BCLP

The GENIUS Act Ushers in a New Era for Stablecoin Regulation

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On July 17, 2025, Congress passed the Guiding and Establishing National Innovation for U.S Stablecoins Act (“GENIUS Act” or “Act”) – a landmark piece of legislation that received bipartisan support and was signed into law by...more

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

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Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Foley & Lardner LLP

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions to Counter Cartel-Linked Fentanyl Trade

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On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...more

K2 Integrity

Risks Increase As U.S. Escalates Pressure Against Mexico With Regulatory Focus On The Financing Of Fentanyl

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The evolving U.S.-Mexico geopolitical relationship is now fundamentally burdened by the growing regulatory, enforcement, and real risks tied to cartel activity, drug trafficking and the fentanyl trade, immigration, and a...more

Alston & Bird

Financial Institutions Permitted to Use Third Parties to Collect Customers’ Taxpayer Identification Numbers for Identity...

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Our Financial Services and White Collar, Government & Internal Investigations Teams examine the Financial Crimes Enforcement Network’s new customer identification program (CIP) exemption that allows banks and credit unions to...more

Lowenstein Sandler LLP

[Webinar] Targeted: How FinCEN's Fentanyl Fight Is Reshaping U.S.–Mexico Financial Compliance - August 7th, 11:00 am - 12:00 pm ET

Lowenstein Sandler LLP on

Join Lowenstein Sandler and Santamarina + Steta for a timely webinar exploring the legal and compliance implications of recent U.S. Treasury actions under the FEND Off Fentanyl Act. The session, featuring Lowenstein's Robert...more

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

Akin Gump Strauss Hauer & Feld LLP

FinCEN Delays Effective Date of Investment Adviser Rule and Intends to Revisit the SEC Customer Identification Program Rule for...

In September 2024, FinCEN issued the Investment Adviser Rule, which aims to “address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial...more

Bracewell LLP

FinCEN's Cartel Crackdown on Three Mexican Financial Institutions: Implications for US Financial Transactions

Bracewell LLP on

It just got much riskier to do business in Mexico. On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a novel set of orders finding three financial institutions in...more

Mayer Brown

FinCEN's First Strike: New Section 311 Powers Target Mexican Financial Institutions Under FEND Off Fentanyl Act

Mayer Brown on

In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more

Cadwalader, Wickersham & Taft LLP

FinCEN Uses the FEND Off Fentanyl Act for First Time to Prohibit Funds Transfers with Three Mexican Financial Institutions

On June 25, 2025, FinCEN announced its first orders under the 2024 FEND Off Fentanyl Act, finding that three Mexican financial institutions—CIBanco S.A. Institución De Banca Multiple (“CIBanco"), Intercam Banco S.A.,...more

Cadwalader, Wickersham & Taft LLP

Midyear Momentum, July 2025 - FinCEN Uses the FEND Off Fentanyl Act for First Time To Prohibit Funds Transfers With Three Mexican...

On June 25, 2025, FinCEN announced its first orders under the 2024 FEND Off Fentanyl Act, finding that three Mexican financial institutions—CIBanco S.A. Institución De Banca Multiple (“CIBanco"), Intercam Banco S.A.,...more

Hogan Lovells

UPDATE #2: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed until September 4

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U.S. financial institutions that conduct funds transfers with the designated Mexican institutions have until 4 September to implement compliance procedures. Transfers of funds involving these designated Mexican institutions...more

Ballard Spahr LLP

Federal banking agencies seek information on actions to address payments fraud

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On June 20, 2025, the Office of the Comptroller of the Currency (OCC), Treasury, the Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) announced they are seeking...more

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...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

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

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