News & Analysis as of September 9, 2025

Regulatory Reform

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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 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

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

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

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FinCEN › Money Laundering › Regulatory Reform

DOJ Official Addresses DeFi Platform Developer Liability Under Money Transmission Statute

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

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

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