News & Analysis as of July 24, 2025

Financial Institutions

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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 -

A New Rule Embraces Modernity in the Customer Identification Process

Bradley Arant Boult Cummings LLP on 7/10/2025

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on 7/10/2025

In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...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

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on 7/1/2025

Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Federal Agencies Issue Order Granting Exemption for Financial Institutions on TIN Collection

Troutman Pepper Locke on 6/30/2025

The Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) (collectively, the agencies), with concurrence from the...more

FDIC Acting Chairman Hill Supports Modernizing Customer Identification Program Requirements

Troutman Pepper Locke on 2/12/2025

In a recent letter to Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill expressed his support for updating the Customer...more

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on 10/24/2024

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Department of the Treasury Releases New AML/CFT Rule for Investment Advisers

Seward & Kissel LLP on 9/13/2024

Who may be interested: Investment Advisers - Quick Take: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule subjecting certain registered investment advisers (RIAs) and...more

FinCEN Proposes Rule to Strengthen AML/CFT Programs

Troutman Pepper Locke on 7/3/2024

On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

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

K&L Gates LLP on 6/27/2024

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

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

Skadden, Arps, Slate, Meagher & Flom LLP on 5/30/2024

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

SEC and FinCEN Propose Customer Identification Program Requirements for Registered Investment Advisers and Exempt Reporting...

Seward & Kissel LLP on 5/29/2024

Who may be interested: Investment Advisers - Quick Take: On May 13, 2024, the SEC and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) jointly proposed a new rule that would require certain...more

FinCEN and SEC propose Customer Identification Program requirements for investment advisers

Eversheds Sutherland (US) LLP on 5/29/2024

Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

FinCEN and SEC Propose Rulemaking Requiring CIP for Investment Advisers

Ballard Spahr LLP on 5/29/2024

On May 13th, the Financial Crimes Enforcement Network (FinCEN) and the Securities Exchange Commission (SEC) issued a joint notice of proposed rulemaking (NPRM) that would require SEC-registered investment advisers (RIAs) and...more

Request for Comments on FinCEN and SEC rule on CIP

King & Spalding on 5/24/2024

The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

Guidepost Solutions LLC on 5/24/2024

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

Jenner & Block on 5/20/2024

In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more

Banking and Consumer Regulatory Digest - March 2024 - 2

Davis Wright Tremaine LLP on 4/17/2024

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

How Many Digits? FinCEN Seeks Comment on Bank Customer Identification Requirements

Mayer Brown on 4/2/2024

On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

Pillsbury Winthrop Shaw Pittman LLP on 3/15/2024

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

FinCEN Proposes New Rule Requiring AML Compliance Programs for Investment Advisers

Cadwalader, Wickersham & Taft LLP on 2/26/2024

On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more

BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]

McGlinchey Stafford on 9/16/2021

The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more

With CDD and Beneficial Ownership Rule in Effect, FinCEN Continues to Clarify and Refine Rules for Financial Institutions

Pillsbury - Global Trade & Sanctions Law on 5/22/2018

Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has taken steps to clarify and refine implementation of the CDD Rules, issuing...more

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

Skadden, Arps, Slate, Meagher & Flom LLP on 5/16/2018

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

Treasury Proposes Regulations That Would Require Private Trust Companies to Establish or Enhance AML Programs and to Identify...

Neal, Gerber & Eisenberg LLP on 9/7/2016

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more

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