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FinCEN › Regulatory Reform

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 -
Buchalter

New Federal Regulatory Regime Provides Foundation for Financial Institutions to be Stablecoin Issuers and Accept Cryptocurrency...

Buchalter on

There has been a flurry of activity in Congress and the White House to liberalize and encourage the development of cryptocurrency as a payment method, including creating a legal regime for depository and non-depository...more

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

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Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

King & Spalding

FinCEN Announces It Will Provide Two-Year Extension of the AML Rule Compliance Date for Registered Investment Advisers and Exempt...

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Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) were less than six months away from the requirement to implement an anti-money laundering and countering the financing of terrorism (AML/CFT) program...more

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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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

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Snell & Wilmer

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

Snell & Wilmer on

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

K&L Gates LLP

United States: AML Reprieve for Investment Advisers

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On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is delaying the effective date of the investment adviser anti-money laundering rule (IA AML Rule) for two years from 1 January 2026 to 1...more

Morrison & Foerster LLP

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

Morrison & Foerster LLP on

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

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On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Cozen O'Connor

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

Cozen O'Connor on

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

Ropes & Gray LLP

FinCEN Delays AML Program Rule for Investment Advisers

Ropes & Gray LLP on

On July 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it intends to delay implementation of its final rule, Anti-Money Laundering/Countering the Financing of Terrorism...more

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Bradley Arant Boult Cummings LLP on

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

McGlinchey Stafford

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on

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

Herbert Smith Freehills Kramer

US Corporate Governance — 2025 Midyear Review

Herbert Smith Freehills Kramer on

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more

Morrison & Foerster LLP

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

Morrison & Foerster LLP on

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

Orrick, Herrington & Sutcliffe LLP

Agencies allow banks to access tax ID numbers from third parties

Orrick, Herrington & Sutcliffe LLP on

On June 27, the OCC, FDIC and NCUA, with the concurrence of FinCEN, granted an exemption allowing banks to use a third party source to obtain customer tax identification numbers (TIN) for customers before opening an account....more

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on

Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Cozen O'Connor

Stablecoins: Navigating the Money Transmitter Minefield & Forthcoming Federal Regulatory Frameworks

Cozen O'Connor on

As digital assets gain traction across financial markets, stablecoins—cryptocurrencies pegged to fiat currencies like the U.S. dollar—are emerging as a practical medium for capital contributions, settlements, and liquidity...more

Dorsey & Whitney LLP

SEC Withdraws 14 Proposed Rules

Dorsey & Whitney LLP on

On June 12, 2025, the SEC formally withdrew 14 rule proposals, all but one of which were introduced during Gary Gensler’s tenure as SEC Chair. The SEC did not provide a reason for the withdrawals but stated that if it decides...more

K2 Integrity

Sanctions Relief For Syria: The United States And European Union Offer Broad Sanctions Relief To Syria

K2 Integrity on

Building on the Quick Take Alert K2 Integrity published on 15 May 2025, this alert outlines the recent developments regarding the easing of Syria sanctions. While the United States has not fully lifted its Syria sanctions, it...more

Eversheds Sutherland (US) LLP

Senators oppose FinCEN’s Interim Final Rule on the Corporate Transparency Act

Eversheds Sutherland (US) LLP on

On May 27, 2025, Senators Sheldon Whitehouse (D-RI) and Charles E. Grassley (R-IA) submitted a comment to US Treasury Secretary Scott Bessent expressing strong opposition to the Financial Crime Enforcement Network’s Interim...more

Whiteford

Client Alert: The GENIUS Act: A Compliance Roadmap for Stablecoin Issuers in 2025

Whiteford on

In April 2025, the Senate Banking Committee voted to advance the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, a landmark bill introduced by Senator Bill Hagerty to regulate the $180 billion...more

Troutman Pepper Locke

Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

Troutman Pepper Locke on

As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

Tarter Krinsky & Drogin LLP

Changes to The Corporate Transparency Act Bring Major Shift to U.S. Reporting Requirements

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Domestic Entities No Longer Required to Disclose Beneficial Ownership Information - The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule on March 21, 2025 (effective...more

Greenberg Glusker LLP

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

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