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FinCEN › Compliance › Banks

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... more +
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 -
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

Cadwalader, Wickersham & Taft LLP

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

Cadwalader, Wickersham & Taft LLP on

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

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

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Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 4- Watergate, Actual Knowledge and Conscious Indifference

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Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

K&L Gates LLP

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

K&L Gates LLP on

Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

Barnea Jaffa Lande & Co.

Risk to Israeli Entities Posed by International Sanctions – What Is the Exposure and What Are the Dangers?

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The executive order signed by United States President Joseph Biden in February 2024 states that the violence being committed by Israeli settlers has reached intolerable levels; poses a serious threat to peace, security, and...more

Mintz - Securities & Capital Markets...

New for 2024: Compliance with the Corporate Transparency Act Necessary for Many Mintz Clients

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Reporting requirements under the Corporate Transparency Act (CTA) are in effect beginning January 1, 2024. Under the CTA, many US entities will be required to provide the personal information of their beneficial owners to the...more

The Volkov Law Group

The Transformative Role of “National AML Priorities” for Compliance in the AML Act of 2020

The Volkov Law Group on

It would be the height of folly to claim that a single theme dominates the AML Act of 2020 (Act). The new law, enacted on January 1 of this year, is an extraordinarily wide-ranging and long overdue reform of the Bank Secrecy...more

Society of Corporate Compliance and Ethics...

Leaked documents reveal how entities evaded sanctions

Society of Corporate Compliance and Ethics... on

Report on Supply Chain Compliance 3, no. 19 (October 1, 2020) - Leaked documents from the Financial Crimes Enforcement Network, including a trove of suspicious activity reports, show how nation-states and entities use...more

NAVEX

Clarifying New Customer Due Diligence (CDD) Guidance on PEPs

NAVEX on

Compliance officers in financial services have long struggled with aspects of Customer Due Diligence, better known as the CDD Rule. This fall, compliance professionals are scratching their heads to know exactly how much due...more

Kelley Drye & Warren LLP

Former US Bank Exec Held Individually Liable for Anti-Money Laundering

Kelley Drye & Warren LLP on

Compliance Failures - On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a consent order assessing a $450,000 civil money penalty against Michael LaFontaine, former Chief...more

Eversheds Sutherland (US) LLP

The OCC’s 2019 annual report addresses anti-money laundering risks for financial institutions

Eversheds Sutherland (US) LLP on

The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more

Nutter McClennen & Fish LLP

Bank Report: October 2019

Nutter McClennen & Fish LLP on

Federal Banking Agencies Adopt Simplified Capital Calculation for Community Banks The federal banking agencies have issued a final rule that will simplify capital requirements for community banks by allowing them to adopt...more

Sheppard Mullin Richter & Hampton LLP

Joint Statement on Digital Assets from CFTC, SEC and FinCEN - a Warning to the Crypto Industry regarding Anti-Money Laundering and...

Sheppard Mullin Richter & Hampton LLP on

The leaders of the U.S. Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, and the U.S. Securities and Exchange Commission (the “Agencies”) issued a joint statement to remind persons engaged in...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tackling the Challenges of Complying With FinCEN’s New Customer Due Diligence Rule

Skadden, Arps, Slate, Meagher & Flom LLP on

Effective May 11, 2018, covered financial institutions are required to comply with the customer due diligence rule (the Rule) that the Financial Crimes Enforcement Network (FinCEN) finalized in May 2016. The Rule mandates the...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

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On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

Bradley Arant Boult Cummings LLP

Banks Should Prepare for Increased Collaboration between IT, Legal and BSA/AML Compliance Departments under New FinCEN Guidance

Bradley Arant Boult Cummings LLP on

Last month, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued an Advisory which provided substantial guidance to financial institutions regarding the scope of information that must be...more

K&L Gates LLP

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

K&L Gates LLP on

This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

Ballard Spahr LLP

Investment Management Update - October 2015

Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

Baker Donelson on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

The Volkov Law Group

FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers

The Volkov Law Group on

FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...more

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