News & Analysis as of September 7, 2025

FinCEN › BSA/AML

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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 Postpones Opening Night for RIA AML Programs

Carlton Fields on 9/2/2025

On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone, for two years, the effective date of a final rule subjecting investment advisers to the anti-money laundering (AML)...more

Wire Fraud: Should banks CYA by tightening up on KYC?

Constangy, Brooks, Smith & Prophete, LLP on 9/2/2025

After a long weekend, Finance Manager Joe sits at his desk to read his emails. One of the emails is from a trusted vendor with whom the Joe communicates on a regular basis, regarding an unpaid invoice that is due immediately....more

Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm on Conspiracy to Operate an Unlicensed...

Ballard Spahr LLP on 8/27/2025

On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was...more

FDIC Approves Use of Pre-Populated Customer Information During Account Opening

Orrick, Herrington & Sutcliffe LLP on 8/12/2025

On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more

FinCEN Issues Order Delaying Effective Date of Investment Adviser Rule

Akin Gump Strauss Hauer & Feld LLP on 8/8/2025

Following an earlier announcement on July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), on August 5, 2025, issued an Exemptive Relief Order (“Order”) to delay for two years,...more

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

Ballard Spahr LLP on 8/6/2025

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

U.S. Senate introduces Act to apply AML/BSA laws to art dealers and auction houses

Ballard Spahr LLP on 8/6/2025

On July 23, 2025, Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Bill Cassidy (R-LA), Andy Kim (D-NJ), and David McCormick (R-PA), introduced the federal Art Market Integrity Act (the...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

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

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

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

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

Eversheds Sutherland (US) LLP on 7/24/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date for certain investment advisers to implement anti-money...more

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

Troutman Pepper Locke on 7/23/2025

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

Morrison & Foerster LLP on 7/23/2025

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on 7/23/2025

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

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

Morrison & Foerster LLP on 7/8/2025

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

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

Troutman Pepper Locke on 6/12/2025

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

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

Gordon Rees Scully Mansukhani on 5/22/2025

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

Recent SEC AML Enforcement Actions and Likely Continued AML Emphasis Under New Administration

Carlton Fields on 4/30/2025

Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

Ballard Spahr LLP on 3/18/2025

We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more

FinCEN Geographic Targeting Order Imposes Additional Recordkeeping and Reporting Requirements

Holland & Knight LLP on 3/14/2025

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more

Crypto Business Compliance: U.S. Licensing and Regulations

Carlton Fields on 3/4/2025

The crypto industry is evolving rapidly, and regulatory enforcement is keeping pace. Businesses engaged in crypto transactions, custody, lending, trading, or payments must navigate know your customer (KYC) and anti-money...more

Patriot Bank Enters Agreement with OCC to Address Regulatory Concerns

Ballard Spahr LLP on 2/25/2025

On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more

Key Considerations After DOJ Announces Shifting Enforcement Priorities

Troutman Pepper Locke on 2/21/2025

On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...more

Lessons From 2024 Anti-Money Laundering Enforcement Actions

K&L Gates LLP on 2/17/2025

In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more

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FinCEN › BSA/AML

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