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FinCEN › Risk Management

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 -
Robinson Bradshaw

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

Robinson Bradshaw on

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

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

Dorsey & Whitney LLP

Investment Adviser Compliance with FinCEN’s AML/CFT Rule

Dorsey & Whitney LLP on

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

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2025

Nutter McClennen & Fish LLP on

The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...more

Ankura

Exam Time: Understanding Exam Ratings

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It is inevitable that your Money Service Business (MSB) will eventually receive a much-anticipated (or in some instances, much-dreaded) Exam Engagement letter from one or more states. MSBs licensed in 40 or more states meet...more

Mayer Brown

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

Mayer Brown on

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

King & Spalding

Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act

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The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more

Paul Hastings LLP

Anti-Money Laundering Enforcement Risk Still Remains for Virtual Asset Services Providers

Paul Hastings LLP on

Despite the Trump administration’s generally favorable stance toward cryptocurrency and blockchain innovation, virtual asset services providers (VASPs) must remain vigilant in complying with anti-money laundering (AML)...more

Morgan Lewis

US Designation of Cartels as Terrorist Organizations Increases Risk of Doing Business in Mexico

Morgan Lewis on

Recent US government actions indicate a possible increase in US financial crimes investigations and enforcement targeting drug cartels and transnational criminal organizations in Latin America....more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

Pillsbury Winthrop Shaw Pittman LLP on

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

ArentFox Schiff

What Private Companies and Family Offices Need to Consider in 2025

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Across all industries, private companies, family offices, and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are 11 issues that...more

McGlinchey Stafford

BOI Reporting Penalties Suspended, No Need to File? Not So Fast

McGlinchey Stafford on

The U.S. Department of Treasury has suspended all penalties and fines for beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. If...more

A&O Shearman

Wolfsberg Group FAQs to help assess risks generated by the emergence of digital assets for AML and CTF purposes

A&O Shearman on

The Wolfsberg Group has published FAQs on defining digital assets. The FAQs propose definitions to be used by financial institutions, policymakers, supervisors and regulators to understand the characteristics of digital...more

The Volkov Law Group

Mitigating Risks of “Interacting” with Cartels and TCOs

The Volkov Law Group on

We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs).  Companies need to understand the laws used to...more

Ballard Spahr LLP

Patriot Bank Enters Agreement with OCC to Address Regulatory Concerns

Ballard Spahr LLP on

On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more

Moritt Hock & Hamroff LLP

CTA Back In Effect; FinCEN Sets New Filing Deadlines

Moritt Hock & Hamroff LLP on

On February 18, 2025, the U.S. District Court for the Eastern District of Texas lifted the nation-wide injunction it issued in January of this year in the case of Smith, et al. v. U.S. Department of the Treasury, which...more

K&L Gates LLP

Lessons From 2024 Anti-Money Laundering Enforcement Actions

K&L Gates LLP on

In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more

Oberheiden P.C.

10 Keys to Conducting an Effective AML/BSA Audit in 2025

Oberheiden P.C. on

Financial institutions need to remain vigilant about managing anti-money laundering and Bank Secrecy Act (AML/BSA) compliance in 2025. As the financial ecosystem becomes increasingly complex, and as transactions increasingly...more

Ankura

Quality Control Unveiled: Insights from Transaction Monitoring

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Ensuring high-quality standards in any organization is an essential ingredient that must be rooted within a company’s Quality Management Program (QMP) – a program that creates a framework to ensure quality....more

Ropes & Gray LLP

Crypto Quarterly Digital Assets, Blockchain and Related Technologies Update

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The landscape of government enforcement, private litigation and federal and state regulation of digital assets, blockchain and related technologies is constantly evolving. Each quarter, Ropes & Gray attorneys analyze...more

K2 Integrity

Fiat Ramps Unlocked: Practical Tips For Banks And Crypto Firms

K2 Integrity on

Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more

Foodman CPAs & Advisors

BIS New Guidance for FI’s Best Practices

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On 10/9/24, the Bureau of Industry and Security (BIS) within the Department of Commerce has issued guidance aimed at financial institutions (FIs), outlining best practices for adherence to the Export Administration...more

NAVEX

How Compliance Teams Can Think About Risk in Modern Times

NAVEX on

A few weeks back the U.S. Financial Crimes Enforcement Network (FinCEN) published a bulletin urging financial firms to do better at identifying deepfakes that fraudsters might use to evade customer due diligence programs. The...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

Perkins Coie on

The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

Latham & Watkins LLP on

On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

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