News & Analysis as of August 12, 2025

Suspicious Activity Reports (SARs)

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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 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

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on 7/24/2025

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...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

Legal Guidance for Financial Integrity and Whistleblower Protection

Friling Law on 7/18/2025

Over the past few years, whistleblowers have become a driving force in uncovering financial misconduct in the U.S. Individuals may report illicit financial activity, including money laundering, sanctions evasion, fraud, and...more

Three Banks Targeted by FinCEN in FEND Off Fentanyl Act Actions: What to Know

Lowenstein Sandler LLP on 6/30/2025

On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...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

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 Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

Buchalter on 3/14/2025

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...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

FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML Program

Ballard Spahr LLP on 10/28/2024

The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”). The Consent Order describes Lake...more

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on 10/22/2024

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

Lowenstein Sandler LLP on 10/15/2024

On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

FinCEN Reports Check Fraud Amounting to $688 Million Over Six Month Period

Ballard Spahr LLP on 10/8/2024

The Financial Crimes Enforcement Network (“FinCEN”) issued last month an in-depth report on check fraud stemming from mail theft (“Report”). This is a pernicious and expanding problem. The Report follows upon a joint alert...more

Investment Adviser Sector and FinCEN

Foodman CPAs & Advisors on 10/1/2024

FinCEN seeks to safeguard the investment adviser sector from illicit finance as evidenced by the issuance of the Final Investment Adviser Rule on 8/28/24 with a compliance date of 1/1/26. The investment adviser sector final...more

Treasury Department Releases Semiannual Regulatory Agenda

Troutman Pepper Locke on 9/27/2024

On August 16, the U.S. Department of the Treasury published its semiannual regulatory agenda in the Federal Register, detailing the agency’s upcoming regulatory actions and priorities. The agenda outlines the proposed, final,...more

FinCEN Expands its Reach with Final Rules for Investment Advisers and the Residential Real Estate Sector

Morrison & Foerster LLP on 9/26/2024

Key Takeaways - •FinCEN has issued two new final rules to significantly expand regulation around certain investment adviser and residential real estate sectors to combat illicit finance in these areas. These highly...more

Federal and State Regulators Increase Scrutiny of Casino AML Practices

Brownstein Hyatt Farber Schreck on 9/24/2024

Recent money laundering-related enforcement actions targeting casinos by both the U.S. Department of Justice (“DOJ”) and state regulators suggest increasing scrutiny of anti-money laundering (“AML”) compliance efforts within...more

Investment Advisers Subject to AML and SARs Requirements

Jones Day on 9/23/2024

The Situation: The Financial Crimes Enforcement Network ("FinCEN") has adopted a rule that subjects certain investment advisers to anti-money laundering/countering the financing of terrorism program ("AML") requirements...more

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

Ballard Spahr LLP on 9/13/2024

Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

Ballard Spahr LLP on 9/11/2024

On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Federal Register...more

Pending FinCEN Investment Adviser Rule: Industry Perspective On Next Steps You Should Be Taking

K2 Integrity on 8/27/2024

On 22 August 2024, K2 Integrity hosted a webinar discussing considerations related to the pending anti-money laundering rule (AML) for investment advisers (IAs) from the Financial Crimes Enforcement Network (FinCEN). The...more

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

Ballard Spahr LLP on 8/5/2024

The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

BSA Filings and Their Utility to Law Enforcement: An Industry Viewpoint

Ballard Spahr LLP on 7/29/2024

In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

Ballard Spahr LLP on 7/29/2024

The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...more

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FinCEN › Financial Crimes › Suspicious Activity Reports (SARs)

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