News & Analysis as of August 17, 2025

Money Services Business

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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 -

Exam Time: Understanding Exam Ratings

Ankura on 5/23/2025

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

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

K&L Gates LLP on 3/20/2025

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

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

Pillsbury Winthrop Shaw Pittman LLP on 3/20/2025

On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more

FinCEN’s Geographic Targeting Order Increases Reporting Obligations for Money Services Businesses Located Near the United...

DLA Piper on 3/13/2025

On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more

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 10/15/2019

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

Application of FinCEN’s regulations to certain business models involving convertible virtual currencies

Eversheds Sutherland (US) LLP on 5/21/2019

On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) issued interpretive guidance1 summarizing the application of the Bank Secrecy Act (BSA) rules to business models “involving money transmission denominated in...more

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Sheppard Mullin Richter & Hampton LLP on 5/15/2019

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

Should You Bank a Virtual Currency Business?

Ward and Smith, P.A. on 9/28/2018

Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more

Anti-Money Laundering Obligations for Virtual Currency Companies

Wilson Sonsini Goodrich & Rosati on 4/4/2018

Virtual currency businesses are under scrutiny by U.S. anti-money laundering (AML) regulators. Earlier this year, U.S Treasury Secretary Steven Mnuchin emphasized that virtual currencies are subject to AML regulations. He...more

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

Akin Gump Strauss Hauer & Feld LLP on 3/2/2017

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

The Banking Stepchild: Money Service Businesses

The Volkov Law Group on 3/22/2016

Sometimes risk analysis can result in paralysis. Finding your risk tolerance and applying it to specific situations requires a nuanced approach. I am always wary of anyone who tells me categorical rules – e.g. we do not...more

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FinCEN › Compliance › Money Services Business

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