News & Analysis as of August 3, 2025

Anti-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 -

Passage of the GENIUS Act: A Turning Point in Stablecoin and Digital Asset Regulation

Cozen O'Connor on 7/22/2025

President Donald J. Trump has signed into law the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins of 2025 or the GENIUS Act of 2025), establishing the first comprehensive federal framework for...more

Can a Failed Privacy Program Lead to Fentanyl Trafficking or OFAC Violations?

Guidepost Solutions LLC on 8/1/2024

In July 2024, the Federal Bureau of Investigation and Department of Treasury’s Financial Crime Enforcement Network and Office of Foreign Assets Control (OFAC) released a joint notice discussing how Mexican-based Transnational...more

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

Cadwalader, Wickersham & Taft LLP on 2/29/2024

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

[Event] 8th Forum on FinTech & Emerging Payment Systems - April 9th - 10th, New York, NY

American Conference Institute (ACI) on 2/28/2024

ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more

FinCEN Seeks Enhanced Oversight of Crypto Mixing

Latham & Watkins LLP on 11/3/2023

A proposed rule would increase Treasury’s insight into non-US crypto mixing transactions to combat illicit activities by malicious actors. On October 19, 2023, the US Department of the Treasury’s Financial Crimes...more

[Event] 2nd Forum on Digital Assets Compliance: AML, Sanctions and Regulatory Oversight - October 17th - 18th, New York, NY

American Conference Institute (ACI) on 9/25/2023

With so many new, emerging risks coming to the forefront, ACI is excited to announce our Digital Assets Compliance: AML, Sanctions and Regulatory Oversight. Unlike other conferences, this highly anticipated event stands apart...more

Andrea Gacki, Former Director of OFAC, Appointed Director of FinCEN

Ballard Spahr LLP on 7/14/2023

Yesterday, the Department of the Treasury announced that Andrea Gacki, who had been serving as the Director of the Office of Foreign Assets Control (OFAC), has been appointed as the Director of the Financial Crimes...more

New Bipartisan Bill Takes Aim at Digital Asset Money Laundering and Terrorism Finance

Cadwalader, Wickersham & Taft LLP on 12/20/2022

On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced in the U.S. Senate a new bipartisan bill, titled "Digital Asset Anti-Money Laundering Act of 2022" (the “Bill”), intended to curb the...more

U.S. Authorities Amplify Enforcement Efforts to Address Financial Crime Risks in the Digital Asset Industry

K2 Integrity on 10/26/2022

The United States Department of the Treasury has continued to signal that it will focus policy, regulatory, and enforcement attention on the financial crime and sanctions risk in the crypto and digital asset ecosystem...more

The CFTC Begins Policing AML Enforcement

Orrick, Herrington & Sutcliffe LLP on 10/22/2020

Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town. The Commodity Futures Trading Commission recently finished its fiscal year with...more

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on 2/13/2020

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Cryptocurrency and OFAC: Beware of the Sanctions Risks

Orrick - On the Chain on 1/24/2020

A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

Ballard Spahr LLP on 12/5/2019

On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

Joint Statement on Digital Assets Highlights AML Regulatory Overlap

Ballard Spahr LLP on 10/14/2019

Leaders of FinCEN, CFTC and SEC Attempt an Intricate Dance of Competing Oversight of Virtual Currency - On October 11, the leaders of the Financial Crimes Enforcement Network (“FinCEN”), the Commodity Futures Trading...more

FinCEN’s New Guidance for Cryptocurrency Businesses – Some Questions Answered, Some New Questions Raised, Careful Consideration a...

Orrick - On the Chain on 6/24/2019

Last month, the Financial Crimes Enforcement Network (FinCEN) released new guidance to clarify when the Bank Secrecy Act (BSA) will apply to businesses that involve cryptocurrencies (what FinCEN refers to as convertible...more

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Sheppard Mullin Richter & Hampton LLP on 5/15/2019

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

FinCEN Shows a Little Bite to Go with Its Bark

Orrick - On the Chain on 4/25/2019

Last week, the Financial Crimes Enforcement Network (FinCEN) backed up its strong public statements about enforcing the anti-money laundering (AML) laws with respect to cryptocurrency by bringing an enforcement action against...more

FinCEN Director Addresses Virtual Currency and Touts Regulatory Leadership and Value of SAR Filings

Ballard Spahr LLP on 8/13/2018

Address Emphasizes Role of SARs in Fighting Illegal Activity, Including Drug Dealing Fueling the Opioid Crisis - Kenneth Blanco, the Director of the Financial Crimes Enforcement Network (“FinCEN”), discussed last week...more

Virtual Currency: Anti-Money Laundering and Terrorist Financing Update

Perkins Coie on 7/26/2018

On July 18, 2018, the Financial Action Task Force (“FATF”), published its report to the July 2018 G20 Finance Ministers and Central Bank Governors’ meeting. The report sets out FATF’s ongoing work to fight money laundering...more

FinCEN’s Beneficial Ownership Rule: More Practical Tips and Answers to Frequently Asked Questions

Ballard Spahr LLP on 4/18/2018

Last year, we posted FinCEN’s Beneficial Ownership Rule: A Practical Guide to Being Prepared for Implementation regarding the Customer Due Diligence Requirements for Financial Institutions Rule (the “Beneficial Ownership...more

FinCEN Issues Guidance for Beneficial Ownership Regulations

The Volkov Law Group on 4/17/2018

Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly...more

The Need for Anti-Money Laundering Regulatory Reform

The Volkov Law Group on 1/19/2018

It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious. Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML...more

Your Daily Dose of Financial News

Robins Kaplan LLP on 1/10/2018

AT&T has dropped plans to sell the Mate 10—the newest smartphone from China’s Huawei Technologies—just before the partnership was to be announced. AT&T gave no reasons for its abrupt reversal, but lawmakers have recently...more

FinCEN Fines Texas Bank $2M for Alleged Failure to Vet and Monitor Mexican Correspondent Banking Relationship – But Touts Bank’s...

Ballard Spahr LLP on 11/8/2017

FinCEN recentlty announced entry of a $2 million assessment against Lone Star National Bank, a private bank operating out of Texas, for the bank’s allegedly willful violations of the Bank Secrecy Act (“BSA”) and inadequate...more

Corporate Shell Games and KYC Requirements

The Volkov Law Group on 5/9/2017

Anti-money laundering professionals are in for a rude awakening. Know Your Customer or KYC requirements are currently kicking up a notch, and will be even more dramatic when the new FinCEN beneficial ownership regulations...more

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