News & Analysis as of July 30, 2025

FinCEN › Regulatory Requirements › AML/CFT

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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 Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on 7/29/2025

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

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

BCLP on 7/29/2025

FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

Financial Institutions Permitted to Use Third Parties to Collect Customers’ Taxpayer Identification Numbers for Identity...

Alston & Bird on 7/28/2025

Our Financial Services and White Collar, Government & Internal Investigations Teams examine the Financial Crimes Enforcement Network’s new customer identification program (CIP) exemption that allows banks and credit unions to...more

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

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

Seward & Kissel LLP on 7/24/2025

On July 21, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was delaying the effective date of its final rule establishing Anti-Money Laundering/Countering the Financing...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

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

Morrison & Foerster LLP on 7/23/2025

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

FinCEN Delays AML Program Rule for Investment Advisers

Ropes & Gray LLP on 7/22/2025

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

Application of New Anti-Money Laundering Regulations to Advisers to Private Funds

Robinson Bradshaw on 7/15/2025

On Sept. 4, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a final rule imposing new anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements on...more

Investment Adviser Compliance with FinCEN’s AML/CFT Rule

Dorsey & Whitney LLP on 7/9/2025

On August 28, 2024, Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) that imposes comprehensive anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements on...more

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

Lowenstein Sandler LLP on 6/24/2025

On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more

Understanding FinCEN’s New AML/CFT Rule for Investment Advisers

Procopio, Cory, Hargreaves & Savitch LLP on 5/20/2025

What You Need to Know Before January 1, 2026 - Certain registered investment advisers (RIAs) and Exempt Reporting Advisors (ERAs) will face new federal compliance and filing requirements in the new year. Starting January 1,...more

Credibly Challenged Podcast: Interview with Ross Delston, Financial Crime Compliance Expert and Former FDIC Attorney

Mayer Brown on 5/9/2025

Matt Bisanz interviews Ross Delston, a financial crime compliance expert and former FDIC attorney. They discuss his views on the trends we should expect to see in financial crimefighting and AML compliance over the next few...more

SEC Charges Investment Adviser - Signaling Importance of Accurate Disclosure of AML Procedures

White & Case LLP on 1/29/2025

The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures. As we...more

GLI British Virgin Islands blockchain and cryptocurrency regulation 2025, seventh edition

Carey Olsen on 1/8/2025

Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

Skadden, Arps, Slate, Meagher & Flom LLP on 5/30/2024

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on 5/21/2024

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

[Webinar] AML/CFT Rules for Investment Advisers - June 12th, 9:30 am PT

K2 Integrity on 5/17/2024

On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

FinCEN's Proposed Streamlined SAR -- The Real Estate Report

Cadwalader, Wickersham & Taft LLP on 2/26/2024

On February 16, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule addressing “Anti-Money Laundering Regulations for Residential Real Estate Transfers.” The proposed rule would, among other...more

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on 2/23/2024

On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024

Perkins Coie on 12/5/2023

Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more

Human Trafficking and Banking: What Compliance Officers Need to Know

K2 Integrity on 1/27/2021

Human trafficking is a global crisis that has an impact on lives around the globe. Over time, there have been many initiatives taken by governments and nonprofits to identify and help victims while promoting enhanced...more

FinCEN Sends Message to the Virtual Currency Industry: The Travel Rule Applies to You, Too

Orrick - On the Chain on 5/28/2020

FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

Ballard Spahr LLP on 3/5/2020

In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

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FinCEN › Regulatory Requirements › AML/CFT

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