News & Analysis as of September 8, 2025

FinCEN › Money Laundering

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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 -

DOJ Refines Illicit Finance Enforcement Approach for DeFi

Alston & Bird on 9/5/2025

Our White Collar, Government & Internal Investigations Group reviews several Department of Justice statements that together signal how it will enforce illicit finance risks in decentralized finance (DeFi), focusing on...more

DOJ Official Addresses DeFi Platform Developer Liability Under Money Transmission Statute

Latham & Watkins LLP on 9/3/2025

DOJ will focus on criminal intent over mere code creation, seeking to balance legal accountability with support for innovation....more

Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm on Conspiracy to Operate an Unlicensed...

Ballard Spahr LLP on 8/27/2025

On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was...more

FinCEN’s Focus on Cryptocurrency Kiosks and Financial Crime

Ballard Spahr LLP on 8/26/2025

On August 4, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice FIN-2025-NTC1 (the “Notice”) to address mounting concerns over regulatory risks related to convertible virtual currency (“CVC”) kiosks, also...more

Treasury Issues Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets

Troutman Pepper Locke on 8/25/2025

On August 18, the U.S. Department of the Treasury issued a Request for Comment, inviting interested members of the public to provide input on innovative methods to detect and mitigate illicit finance risks involving digital...more

Toothless: How Proposed Changes to the Corporate Transparency Act Diminish its Efficacy

Ankura on 8/18/2025

17 Back in 2021, the U.S. Government passed the Corporate Transparency Act (CTA), which was an effort to improve upon the Bank Secrecy Act (BSA) and bolster the nation’s defenses against Money Laundering and Terrorist...more

The Tornado Cash Trial’s Mixed Verdict: Implications for Developer Liability

Mayer Brown on 8/15/2025

On August 6, 2025, following a four-week trial, a jury in the Southern District of New York delivered a mixed verdict in the criminal case against Tornado Cash co-founder Roman Storm. The jury convicted Storm of conspiring to...more

FinCEN Targets Three Mexican Financial Institutions for Fentanyl Trafficking

Patomak Global Partners on 8/13/2025

The Trump Administration has repeatedly signaled its prioritization of targeting traffickers of synthetic opioids, especially fentanyl. On January 20, 2025, President Trump signed an Executive Order “creating a process by...more

FinCEN Addresses Increased Fraud Involving Convertible Virtual Currency Kiosks

Perkins Coie on 8/11/2025

Key Takeaways - - The Financial Crimes Enforcement Network’s recently issued notice, which addresses regulations and increased rates of fraud surrounding convertible virtual currency kiosks, carries significant implications...more

FinCEN Warns Financial Institutions of Illicit Activity at Crypto Kiosks

Sheppard Mullin Richter & Hampton LLP on 8/8/2025

On August 4, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice warning financial institutions about escalating illicit activity involving convertible virtual currency (CVC) kiosks. The notice cites...more

U.S. Senate introduces Act to apply AML/BSA laws to art dealers and auction houses

Ballard Spahr LLP on 8/6/2025

On July 23, 2025, Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Bill Cassidy (R-LA), Andy Kim (D-NJ), and David McCormick (R-PA), introduced the federal Art Market Integrity Act (the...more

FFFrictions, August 2025 - FinCEN Restrictions on Certain Mexican Banks

Cadwalader, Wickersham & Taft LLP on 8/1/2025

New and significant prohibitions against financial transactions between U.S. financial institutions and three Mexican financial institutions are set to go into effect in a little over a month on September 4, 2025. In late...more

U.S. FinCEN's Order Targeting CIBanco Will Upend Mexican Fiduciary Market

Foley & Lardner LLP on 7/31/2025

In late June 2025, the U.S. Treasury’s FinCEN (Financial Crimes Enforcement Network), under new authorities granted pursuant to the Fentanyl Sanctions Act, the FEND Off Fentanyl Act, and in line with President Trump’s...more

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions to Counter Cartel-Linked Fentanyl Trade

Foley & Lardner LLP on 7/29/2025

On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...more

[Webinar] Targeted: How FinCEN's Fentanyl Fight Is Reshaping U.S.–Mexico Financial Compliance - August 7th, 11:00 am - 12:00 pm ET

Lowenstein Sandler LLP on 7/28/2025

Join Lowenstein Sandler and Santamarina + Steta for a timely webinar exploring the legal and compliance implications of recent U.S. Treasury actions under the FEND Off Fentanyl Act. The session, featuring Lowenstein's Robert...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

FinCEN's Cartel Crackdown on Three Mexican Financial Institutions: Implications for US Financial Transactions

Bracewell LLP on 7/24/2025

It just got much riskier to do business in Mexico. On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a novel set of orders finding three financial institutions in...more

The Anti-Money Laundering Quarterly - July 2025

Morrison & Foerster LLP on 7/17/2025

Designed for busy in-house counsel and compliance professionals, this newsletter summarizes some of the most important domestic and international Anti-Money Laundering (AML) regulatory and enforcement developments from the...more

UPDATE #2: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed until September 4

Hogan Lovells on 7/11/2025

U.S. financial institutions that conduct funds transfers with the designated Mexican institutions have until 4 September to implement compliance procedures. Transfers of funds involving these designated Mexican institutions...more

FinCEN Issues First Transaction Ban on Certain Mexico-Based Financial Institutions

Morgan Lewis on 7/10/2025

In a historic first, the US Department of the Treasury’s Financial Crimes Enforcement Network recently published orders prohibiting transactions with covered Mexico-based financial institutions. On June 30, 2025, the US...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

FinCEN Designates Three Mexican Financial Institutions Under New Section 311 Authority: First Use of Expanded Powers Under FEND...

Mayer Brown on 7/3/2025

On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more

FinCEN’s Groundbreaking 2313a Orders: What U.S. Banks Need to Know About the Crackdown on Mexican Cartel-Linked Financial...

Bradley Arant Boult Cummings LLP on 7/3/2025

In a historic move that signals a new era in the fight against illicit opioid trafficking and money laundering, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued its first-ever...more

FinCEN Designates Three Mexican Financial Institutions as Primary Money Laundering Concerns Linked to Opioid Trafficking

Ballard Spahr LLP on 7/3/2025

On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued three orders designating CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. (collectively,...more

FinCEN Uses “Special Measures” To Combat Fentanyl Money Laundering, Raising Concerns Around Targeted Mexican Financial...

Perkins Coie on 7/2/2025

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) took a historic step in combating the fentanyl crisis on June 25, 2025, by exercising, for the first time, the expansive authorities granted...more

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FinCEN › Money Laundering

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