News & Analysis as of

Financial Institutions Money Laundering

Orrick, Herrington & Sutcliffe LLP

Treasury seeks public input on innovative methods to detect illicit digital asset activity

On August 18, the Treasury issued a request for public comment on technologies and strategies to help financial institutions identify and mitigate illicit financial risks involving digital assets. The notice solicited...more

Conyers

Regulatory & Risk Advisory Review: Cayman Islands – April to June 2025

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Welcome to the latest edition of our Regulatory & Risk Advisory Review. In this issue, we explore key regulatory updates and emerging trends to help you stay informed and ahead in today’s dynamic compliance environment. The...more

A&O Shearman

PEP talk revisited: revised UK guidance on treatment of PEPs

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The UK Financial Conduct Authority (FCA) has issued finalised guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes. There is no significant shift in the FCA’s expectations of...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

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

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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

Hogan Lovells

PEP talk: The UK FCA issues final guidance on the treatment of politically exposed persons

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The Financial Conduct Authority (“the FCA”) has published final guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes, which updates its Guidance issued in 2017 (“the 2017...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

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

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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

Jones Day

Direct Supervisory Powers of the New European Anti-Money Laundering Authority

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The European Union Anti-Money Laundering ("AML") package includes Regulation (EU) 2024/1620 of the European Parliament and of the Council of May 31, 2024, establishing the Authority for Anti-Money Laundering and Countering...more

Bracewell LLP

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

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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

American Conference Institute (ACI)

[Webinar] Top 5 Game-Changing Regulatory Shifts Impacting Financial Compliance and Board Accountability - September 24th, 1:00 pm...

Don’t miss this complimentary webinar spotlighting the five most pressing regulatory developments reshaping compliance in Canada’s financial sector. From board-level liability, to shifting enforcement priorities, get up to...more

DLA Piper

Chile: Key Changes to Constitutional Bank Secrecy Protections

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Since 2023, the Chilean Congress has been discussing a bill that creates the Economic Intelligence Subsystem, which would include the Financial Analysis Unit (UAF), the Internal Revenue Service (SII), and the National Customs...more

Troutman Pepper Locke

OCC Patriot Bank Order Spotlights AML Issues For Managers

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On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law....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

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

Carey Olsen

Bermuda leads the way on digital transformation

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The surge in adoption of digital technologies and AI is rapidly changing the business, investment and security environments. The global demand for improved and increased digital infrastructure capacity, resilience, speed and...more

Harris Beach Murtha PLLC

The DOJ’s Top Priorities in White Collar Crime

The Department of Justice (DOJ), through the Office of the Assistant Attorney General, has issued a memorandum outlining DOJ’s primary points of focus in white-collar crime. The memo details how white-collar crime is...more

Ballard Spahr LLP

FinCEN Designates Three Mexican Financial Institutions as Primary Money Laundering Concerns Linked to Opioid Trafficking

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On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued three orders designating CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. (collectively,...more

Perkins Coie

FinCEN Uses “Special Measures” To Combat Fentanyl Money Laundering, Raising Concerns Around Targeted Mexican Financial...

Perkins Coie on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) took a historic step in combating the fentanyl crisis on June 25, 2025, by exercising, for the first time, the expansive authorities granted...more

Skadden, Arps, Slate, Meagher & Flom LLP

Treasury Targets Mexican Financial Institutions Linked to Cartels Using New Fentanyl Sanctions Authority

On June 25, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying three Mexican financial institutions as being of primary money laundering concern in connection with...more

Snell & Wilmer

FinCEN Invokes New 2313a Authority Against Three Mexican Financial Institutions

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On June 25, 2025, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued unprecedented orders under the newly enacted 21 U.S.C. § 2313a authority, targeting three Mexico-based financial institutions:...more

Hogan Lovells

UPDATE: Effective date regarding FinCEN’s new Section 2313a Orders against three Mexican financial institutions

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U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions have until 21 July to implement compliance procedures. Transfers of funds involving these designated Mexican...more

Blake, Cassels & Graydon LLP

Refonte majeure du cadre des sanctions établi dans la législation canadienne sur le recyclage des produits de la criminalité

Le 3 juin 2025, le nouveau gouvernement fédéral du Canada a présenté le projet de loi C-2 (le « projet de loi »), la Loi visant une sécurité rigoureuse à la frontière, en première lecture à la Chambre des communes. Le projet...more

Ankura

Green Gold and Shadow Networks: Financial Crime in the Illegal Wildlife Trade

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What does the silent extinction of endangered species reveal about the hidden corridors of global finance? As financial transactions and environmental health become increasingly linked, a troubling reality emerges: illegal...more

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