News & Analysis as of

Financial Institutions Money Services Business

Ankura

Crafting Effective Public Comments: How and Why You Should Participate in the Rulemaking Process

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When regulators propose a new rule, financial institutions can often find themselves pushed into a reactionary position, left to deal with consequences that rule makers may not have foreseen. Once a rule hits the books, legal...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

Ankura

Exam Time: Understanding Exam Ratings

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It is inevitable that your Money Service Business (MSB) will eventually receive a much-anticipated (or in some instances, much-dreaded) Exam Engagement letter from one or more states. MSBs licensed in 40 or more states meet...more

King & Spalding

Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act

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The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more

K&L Gates LLP

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

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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

The Volkov Law Group

OFAC Fines U.S. Person $1 Million for Multiple Violations of Sanctions Regime Against Iran

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In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations...more

Wilson Sonsini Goodrich & Rosati

Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions

Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more

Troutman Pepper Locke

Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros...

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In this episode of Payments Pros, Keith Barnett is joined by Eli Polanco, founder and CEO of Nivelo, to discuss critical issues in payroll processing. They highlight the significant impact that the Money Transmitter...more

Ballard Spahr LLP

PA Department of Banking and Securities: Virtual Currency is “Money”

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On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more

Ballard Spahr LLP

Democratic Senators continue to pressure Zelle and other payment apps to change fraud policies

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On February 15, 2024, Senators Sherrod Brown (D-OH), Jack Reed (D-RI) and Elizabeth Warren (D-MA) sent a letter to Zelle seeking clarification of its reimbursement policy for victims of imposter scams and urging Zelle to...more

Harris Beach Murtha PLLC

[Webinar] Third Party Risk is Your Risk - January 24th, 11:00 am - 12:00 pm EST

• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more

Hudson Cook, LLP

Florida Regulator Clarifies Money Transmitter Licensing Exemptions (or lack thereof)

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Among the many state licenses that can impact financial services companies, money transmitter licensing can be among the harder to figure out. In addition to uncertainties about digital currency and developing technologies,...more

Kelley Drye & Warren LLP

Treasury Department Announces Largest Settlement in History and Severe Penalties Against Binance

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On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more

McGlinchey Stafford

Podcast: Deep Dive Into Payments: Impacts of Money Transmission Laws [More with McGlinchey, Ep. 59]

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The next item in McGlinchey's Deep Dive into Payments Series is a podcast on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money...more

McGlinchey Stafford

Deep Dive Into Payments: Impacts of Money Transmission Laws

McGlinchey Stafford on

The next item in McGlinchey’s Deep Dive into Payments Series is on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money transmission...more

Ballard Spahr LLP

Bipartisan group of Senators re-introduce Digital Asset Money Laundering Act

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On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing...more

Ballard Spahr LLP

Bipartisan Group of Senators Re-Introduce the Digital Asset Money Laundering Act

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Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs - On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more

Orrick, Herrington & Sutcliffe LLP

Iowa modernizes money transmission provisions

The Iowa governor recently signed HF 675 to revise certain provisions of the Uniform Money Transmission Modernization Act. The Act is designed to eliminate unnecessary regulatory burden and harmonize the licensing and...more

Troutman Pepper Locke

Bank Secrecy Act's Crypto Expansion Is on the Horizon

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The Dec. 14, 2022, introduction of the Digital Asset Anti-Money Laundering Act by Sens. Elizabeth Warren, D-Mass., and Roger Marshall, R-Kan., marks the end of a tumultuous year in the cryptocurrency industry that saw a...more

Orrick, Herrington & Sutcliffe LLP

Treasury announces strategy to address financial institution de-risking

The U.S. Treasury Department recently released its “first of its kind” strategy to address financial institution de-risking. Mandated by the Anti-Money Laundering Act of 2020, the 2023 De-Risking Strategy examines customer...more

Blake, Cassels & Graydon LLP

De nouvelles modifications à la législation canadienne en matière de lutte contre le recyclage des produits de la criminalité

Le 21 avril 2023, le gouvernement du Canada a déposé un avis de motion de voies et moyens visant à mettre en œuvre certaines dispositions du budget fédéral de 2023 (le « Budget 2023 »). Comme nous l’avons mentionné plus tôt...more

Blake, Cassels & Graydon LLP

More Changes to Canadian Anti-Money Laundering Legislation

On April 21, 2023, the Canadian government introduced the Notice of Ways and Means Motion to implement certain provisions of the 2023 federal budget. As we noted earlier this month, certain changes were proposed to the...more

Sullivan & Worcester

Compliance Alert! Regulated Entities Gear Up for the UK's Economic Crime Levy

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If your organisation is both supervised under the UK Money Laundering Regulations (“MLR”) and your UK Revenue exceeds £10.2 million per year, if you are not already, you will need to prepare for the forthcoming Economic Crime...more

BakerHostetler

Applying the Bank Secrecy Act, FinCEN Regulations, and Sanctions to the Nascent NFT Market

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Non-fungible tokens (NFTs) often involve two areas with known money laundering and terrorist financing risks: cryptocurrencies and high-value assets, like art. As detailed below, the U.S. Treasury Department’s Financial...more

Sheppard Mullin Richter & Hampton LLP

FinCEN Highlights Responsible Crypto Innovation, Warns Service Providers

On May 19, Alessio Evangelista, the Associate Director of the Enforcement and Compliance Division of FinCEN, presented at the Chainalaysis Links Conference on the topic of “Intersection of Cryptocurrencies and National...more

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