News & Analysis as of July 30, 2025

Compliance

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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

Risks Increase As U.S. Escalates Pressure Against Mexico With Regulatory Focus On The Financing Of Fentanyl

K2 Integrity on 7/29/2025

The evolving U.S.-Mexico geopolitical relationship is now fundamentally burdened by the growing regulatory, enforcement, and real risks tied to cartel activity, drug trafficking and the fentanyl trade, immigration, and a...more

Exam Time: Understanding Exam Ratings

Ankura on 5/23/2025

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

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

What Private Companies and Family Offices Need to Consider in 2025

ArentFox Schiff on 3/10/2025

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

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

McGlinchey Stafford on 3/6/2025

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

Mitigating Risks of “Interacting” with Cartels and TCOs

The Volkov Law Group on 2/25/2025

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

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

Oberheiden P.C. on 2/12/2025

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

Crypto Quarterly Digital Assets, Blockchain and Related Technologies Update

Ropes & Gray LLP on 1/28/2025

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

Fiat Ramps Unlocked: Practical Tips For Banks And Crypto Firms

K2 Integrity on 1/16/2025

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

How Compliance Teams Can Think About Risk in Modern Times

NAVEX on 11/27/2024

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

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

Perkins Coie on 8/23/2024

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

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

Latham & Watkins LLP on 8/5/2024

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

Regulatory Roundup for May 2024

SEC Compliance Consultants, Inc. (SEC³) on 5/30/2024

SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more

CTA Compliance Obligations for CTA Participants: Reporting Companies, Beneficial Owners, and Third-Party Preparers

Dorsey & Whitney LLP on 5/10/2024

In an evolving (and somewhat disjointed) process, FinCEN has been providing guidance to persons and entities that are responsible for filing required beneficial ownership information (“BOI”) reports to FinCEN, as well as to...more

Investment Advisers and Generative AI

Guidepost Solutions LLC on 3/26/2024

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Exercise Caution in Corporate Transparency Act Compliance Matters

Clark Hill PLC on 3/22/2024

Threat actors never miss an opportunity to use recent events to infect computer systems or quickly and easily gather personal information. The Corporate Transparency Act (“CTA”) is just such an opportunity and businesses and...more

Client Alert: DOJ Announces New Whistleblower Rewards Program and Enhanced Focus on AI-Related Risks

Jenner & Block on 3/15/2024

Continuing to prioritize corporate criminal enforcement, the Department of Justice (DOJ) announced two new steps it is taking to identify potential corporate misconduct and evaluate companies’ compliance programs. Deputy...more

Risk to Israeli Entities Posed by International Sanctions – What Is the Exposure and What Are the Dangers?

Barnea Jaffa Lande & Co. on 2/23/2024

The executive order signed by United States President Joseph Biden in February 2024 states that the violence being committed by Israeli settlers has reached intolerable levels; poses a serious threat to peace, security, and...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

Opportunities, Risks, and Compliance in the Digital Assets Space

K2 Integrity on 10/3/2022

On 14 September 2022, K2 Integrity hosted a webinar on considerations in the digital assets space. K2 Integrity Board Member Christopher Brummer and AML/CFT experts Mariano Federici and Alex Levitov discussed the current...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 financial institutions to be “vigilant” for Russia sanctions violations

Eversheds Sutherland (US) LLP on 3/21/2022

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....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

Everything Compliance-Episode 12

Thomas Fox - Compliance Evangelist on 6/8/2017

Show Notes for Episode 12, the Summer Haze Edition The dog days of summer are on the horizon and the Houston Astros lead the major leagues in winning percentage. Coincidence that the US pulls out of the Paris Climate Accords...more

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