News & Analysis as of August 3, 2025

FinCEN › Data Collection › 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... 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 -

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

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

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on 11/28/2023

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Is the “FinCEN Query” a Gateway to Convergence?

Foodman CPAs & Advisors on 9/4/2020

FinCEN’s (a bureau of the U.S. Department of the Treasury) primary purpose is protecting the financial system from illicit use, combating money laundering, and promoting national security through the collection, analysis,...more

U.S. Senate Considering Update to Federal Anti-Money Laundering System

Foley Hoag LLP - White Collar Law &... on 9/30/2019

A bipartisan group of Senators, with the support of the American Bankers Association, recently introduced bill S.2563, known as the ILLICIT Cash Act. The acronym “ILLICIT” stands for “Improving Laundering Laws and Increasing...more

Annual Compliance Obligation Reminders

Vedder Price on 2/16/2018

Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more

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