News & Analysis as of August 1, 2025

FinCEN

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

FinCEN to Postpone Effective Date and Reopen Anti-Money Laundering Rule for Investment Advisers

Goodwin on 8/1/2025

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

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

Foley & Lardner LLP on 7/31/2025

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

Key Measures for Mexican Entities to Prevent FinCEN Scrutiny

Foley & Lardner LLP on 7/31/2025

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

FinCEN Announces Intention to Postpone Effective Date of Anti-Money Laundering Rule for Registered Investment Advisers and Exempt...

Haynes Boone on 7/31/2025

FinCEN will work through the rulemaking process to formally extend the IA AML Rule effective date and intends to provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective...more

FinCEN Delays Investment Adviser AML/CFT Rule to January 2028: What Fund Managers Should Know

Fenwick & West LLP on 7/31/2025

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of its 2024 investment advisor AML rule for registered investment...more

The GENIUS Act Ushers in a New Era for Stablecoin Regulation

BCLP on 7/30/2025

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

Treasury Postpones Effective Date of Investment Adviser AML Rule, Plans Revisions

Wilson Sonsini Goodrich & Rosati on 7/30/2025

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced that it intends to postpone the effective date of the final rule establishing anti-money laundering (AML) and suspicious...more

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on 7/29/2025

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

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

BCLP on 7/29/2025

FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

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

Foley & Lardner LLP on 7/29/2025

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

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

K2 Integrity on 7/29/2025

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

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

Alston & Bird on 7/28/2025

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

[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 7/28/2025

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

FinCEN Announces It Will Provide Two-Year Extension of the AML Rule Compliance Date for Registered Investment Advisers and Exempt...

King & Spalding on 7/25/2025

Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) were less than six months away from the requirement to implement an anti-money laundering and countering the financing of terrorism (AML/CFT) program...more

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

Ballard Spahr LLP on 7/25/2025

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

FinCEN Announces Postponement and Reopening of the Investment Adviser Anti-Money Laundering Rule

Dinsmore & Shohl LLP on 7/25/2025

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 final rule establishing the investment adviser anti-money...more

FinCEN Postpones New AML Rule for Investment Advisers

Latham & Watkins LLP on 7/25/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

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

Snell & Wilmer on 7/24/2025

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

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

Akin Gump Strauss Hauer & Feld LLP on 7/24/2025

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

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FinCEN

FinCEN to Postpone Effective Date and Reopen Anti-Money Laundering Rule for Investment Advisers

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

Key Measures for Mexican Entities to Prevent FinCEN Scrutiny

FinCEN Announces Intention to Postpone Effective Date of Anti-Money Laundering Rule for Registered Investment Advisers and Exempt...

FinCEN Delays Investment Adviser AML/CFT Rule to January 2028: What Fund Managers Should Know

The GENIUS Act Ushers in a New Era for Stablecoin Regulation

Treasury Postpones Effective Date of Investment Adviser AML Rule, Plans Revisions

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

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

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

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

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

FinCEN Announces It Will Provide Two-Year Extension of the AML Rule Compliance Date for Registered Investment Advisers and Exempt...

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

FinCEN Announces Postponement and Reopening of the Investment Adviser Anti-Money Laundering Rule

FinCEN Postpones New AML Rule for Investment Advisers

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

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

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

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

FinCEN Postpones Investment Adviser AML Rule Until 2028

Investment adviser anti-money laundering rule postponed and reopened for further review

United States: AML Reprieve for Investment Advisers

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

FinCEN

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