News & Analysis as of August 2, 2025

FinCEN › Risk Management › Banking Sector

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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... 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 -

[Webinar] Targeted: How FinCEN's Fentanyl Fight Is Reshaping U.S.–Mexico Financial Compliance - August 7th, 11:00 am - 12:00 pm ET

Lowenstein Sandler LLP on 7/28/2025

Join Lowenstein Sandler and Santamarina + Steta for a timely webinar exploring the legal and compliance implications of recent U.S. Treasury actions under the FEND Off Fentanyl Act. The session, featuring Lowenstein's Robert...more

A New Rule Embraces Modernity in the Customer Identification Process

Bradley Arant Boult Cummings LLP on 7/10/2025

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

Nutter Bank Report: June 2025

Nutter McClennen & Fish LLP on 6/30/2025

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

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

Summer Regulatory Round-Up | July 2024

Cadwalader, Wickersham & Taft LLP on 7/26/2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more

Banking and Consumer Regulatory Digest - February 2024 - 3

Davis Wright Tremaine LLP on 3/11/2024

Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Nutter Bank Report: February 2024

Nutter McClennen & Fish LLP on 2/29/2024

The U.S. Department of Justice (DOJ) and state authorities have agreed to a consent order with a large national bank to resolve allegations that the bank engaged in a pattern or practice of lending discrimination by affecting...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

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

Sheppard Mullin Richter & Hampton LLP on 2/19/2024

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

Nutter Bank Report: December 2023

Nutter McClennen & Fish LLP on 12/29/2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Banks – What Should You Know? Civil Liability for Failure to Detect Human Trafficking

Moore & Van Allen PLLC on 12/15/2022

In 2020, we wrote about the increased regulatory attention on financial institutions’ obligations to detect and respond to human trafficking. In 2021, we wrote about how anti-human trafficking programs fit squarely in banks’...more

Domestic Terrorism: Understanding the Threat and How Banks Can Counter It

K2 Integrity on 10/26/2022

Domestic terrorism is not a new threat in America, but in recent years we have seen a significant and horrific increase in violent attacks and activities carried out by individuals and groups motivated by a range of radical...more

Marijuana Banking in 2022: Lessons Learned and Best Practices

Venable LLP on 8/4/2022

As we pass the halfway mark of 2022, it's a good time to reflect on what has happened, or not happened, with respect to the legal framework for the provision of financial services to marijuana-related businesses...more

FinCEN Warns Against Evasion of Russian Sanctions

Goodwin on 3/14/2022

In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

CannaBanking in Alabama: Will Financial Institutions See Green?

Bradley Arant Boult Cummings LLP on 3/8/2022

Medical cannabis is on the way in Alabama. What does that mean for Alabama banks? The implications of this development are enormous for the financial services industry in Alabama, as each institution will soon have to...more

SEC Proposes Changes to Private Fund Regulation

Goodwin on 2/11/2022

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on 1/7/2022

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on 12/17/2021

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Fintech Legal Report - July 2021

Perkins Coie on 7/20/2021

President Biden Issues an Executive Order on Competition with Implications for Financial Institutions - On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. The...more

Will Cannabis Legalization Provide Safety for Financial Institutions?

Clark Hill PLC on 3/22/2021

On this episode of the Credit Eco to Go podcast with Joann Needleman, there is much speculation that 2021 could be the year that Congress enacts meaningful legislation to allow marijuana related businesses (MRBs) to access...more

OCC Confirms National Banks Can Hold (Certain) Stablecoin Reserves

K&L Gates LLP on 9/25/2020

On 21 September, the Office of the Comptroller of the Currency (OCC) issued Interpretive Letter Number 11721 (Letter) confirming that national banks and federal savings associations (collectively, national banks) can hold...more

FinCEN demystifies risk-focused Bank Secrecy Act/anti-money laundering supervision

Eversheds Sutherland (US) LLP on 7/29/2019

Last week, the Financial Crimes Enforcement Network (FinCEN) and its regulatory partners issued a joint statement in an effort to increase transparency around risk-focused Bank Secrecy Act/anti-money laundering supervision....more

When Bank Account Activity is not Consistent with the Customer’s Business

Foodman CPAs & Advisors on 7/23/2018

According to the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) states that the main focus for Financial Institution ought to be on the reporting of suspicious activities....more

Is Your AML Program Up to the Task?

K2 Integrity on 3/19/2018

Fulfilling today’s requirements for anti-money laundering and counterterrorism financing/sanctions compliance is no easy task for financial institutions. ...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

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