News & Analysis as of August 25, 2025

Financial Services Industry

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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 -

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

Troutman Pepper Locke on 7/23/2025

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Legal Guidance for Financial Integrity and Whistleblower Protection

Friling Law on 7/18/2025

Over the past few years, whistleblowers have become a driving force in uncovering financial misconduct in the U.S. Individuals may report illicit financial activity, including money laundering, sanctions evasion, fraud, and...more

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

Troutman Pepper Locke on 6/12/2025

Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

FinCEN’s New Interim Final Rule on Beneficial Ownership Information Reporting

IR Global on 4/11/2025

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced significant changes to the Beneficial Ownership Information Reporting (BOIR) requirements (Department of the Treasury, 2025). This new interim...more

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

Pillsbury Winthrop Shaw Pittman LLP on 3/20/2025

On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

Ballard Spahr LLP on 3/18/2025

We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more

FinCEN Issues Geographic Targeting Order for U.S. Southwestern Border

Alston & Bird on 3/17/2025

Our Financial Services and White Collar, Government & Internal Investigations Groups unpack the Financial Crimes Enforcement Network’s new geographic targeting order aimed at combatting money laundering and other illegal...more

FinCEN Geographic Targeting Order Imposes Additional Recordkeeping and Reporting Requirements

Holland & Knight LLP on 3/14/2025

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more

Client Alert: CTA Enforcement Suspended – Key Updates on Filing Requirements

Whiteford on 3/5/2025

On March 2, 2025, the U.S. Department of the Treasury t (“Treasury”) announced that it will not impose penalties, fines, or pursue enforcement actions against U.S. companies, citizens, or their beneficial owners for failing...more

Yo-Yo-Yo: CTA is Back

Ruder Ware on 2/19/2025

The Corporate Transparency Act (CTA) and its reporting requirements are back in effect. This afternoon, a federal district court in Texas granted the U.S. government’s motion to stay (i.e., pause) the nationwide CTA...more

Content Creators and the Risks for Money Laundering

Ankura on 2/7/2025

YouTube is a force of nature. If one requires information on how to build a cabin from mud and twigs, there is a video for that. If you want to watch someone clean up crime scenes, there is a whole YouTube channel for that...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 Confirms Suspension of Corporate Transparency Act

Mayer Brown on 12/17/2024

Join us for a new episode of Financial Services Focus with partners Gina Parlovecchio and Matthew Bisanz, and associate Kelly Truesdale, as they discuss FinCEN’s recent confirmation that reporting companies are not required...more

FinCEN Reports Check Fraud Amounting to $688 Million Over Six Month Period

Ballard Spahr LLP on 10/8/2024

The Financial Crimes Enforcement Network (“FinCEN”) issued last month an in-depth report on check fraud stemming from mail theft (“Report”). This is a pernicious and expanding problem. The Report follows upon a joint alert...more

Jeopardy Question: Rates and Leaves -- Answer: What Are Things That Are Dropping?

Cadwalader, Wickersham & Taft LLP on 10/2/2024

FinCEN Issues Final Rule Designed to Combat Money-Laundering in Residential Real Estate Transactions: Money It’s a Gas, Grab That Cash With Both Hands and Make a Stash....more

Investment Advisers Subject to AML and SARs Requirements

Jones Day on 9/23/2024

The Situation: The Financial Crimes Enforcement Network ("FinCEN") has adopted a rule that subjects certain investment advisers to anti-money laundering/countering the financing of terrorism program ("AML") requirements...more

FinCEN Publishes Updated FAQs Regarding CTA Filings for Dissolved Entities and Withdrawn Foreign Entities

Troutman Pepper Locke on 9/16/2024

On September 10, the Financial Crimes Enforcement Network (FinCEN) published updated guidance in the form of new and revised frequently asked questions (FAQs), C.14-C.16 and G.4, regarding beneficial ownership information...more

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

Ballard Spahr LLP on 9/13/2024

Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

Ballard Spahr LLP on 9/11/2024

On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Federal Register...more

Public Companies Quarterly Update (Q2 2024)

Saul Ewing LLP on 8/2/2024

Welcome to Saul Ewing’s Public Companies Quarterly Update series. Our intent is to, on a quarterly basis, highlight important legal developments of which we think public companies should be aware. This edition is related to...more

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

Ballard Spahr LLP on 7/16/2024

On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

FinCEN Issues Reminder to Financial Institutions to Identify and Report Elder Financial Exploitation

Ballard Spahr LLP on 6/24/2024

On June 14, 2024, President Biden declared June 15th World Elder Abuse Awareness Day. In honor of the day, the Financial Crimes Enforcement Network (FinCEN) reminded financial institutions (FIs) to remain vigilant in...more

The Shadow Financial System

White & Case LLP on 6/18/2024

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

CTA + CPAs: Insights from the Maryland Attorney General

Lerch, Early & Brewer on 5/22/2024

Since the Corporate Transparency Act (“CTA”) went into effect earlier this year many Certified Public Accountants (“CPAs”) have been hesitant to assist clients with CTA compliance. This hesitancy stems, at least in part,...more

To Infinity and Beyond: FinCEN Announces Access Rule Schedule

Mayer Brown on 4/26/2024

On April 18, 2024, the Financial Crimes Enforcement Network (“FinCEN”) announced its revised implementation schedule for providing access to the beneficial ownership information (“BOI”) reports. The tentative, revised...more

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