News & Analysis as of

FinCEN Risk Management Suspicious Activity Reports (SARs)

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 -
Pillsbury Winthrop Shaw Pittman LLP

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

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

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

Nutter McClennen & Fish LLP

Nutter Bank Report: December 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

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

K2 Integrity

Human Trafficking and Banking: What Compliance Officers Need to Know

K2 Integrity on

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

K2 Integrity

Secrets of Great AML Compliance Programs

K2 Integrity on

Six steps can take institutions beyond merely good. What makes for a great anti-money laundering compliance program? This is not a pie-in-the-sky idea. As financial institutions strive to keep up with evolving regulations...more

Moore & Van Allen PLLC

Human Trafficking Awareness – What Financial Institutions Need to Know

Moore & Van Allen PLLC on

Anti-Money Laundering and Know Your Customer departments at financial institutions are on the front lines of human trafficking. Not only does enhanced transaction monitoring help law enforcement identify trafficking...more

Ballard Spahr LLP

AMA Updates AML Best Practices for AML Compliance

Ballard Spahr LLP on

AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more

White & Case LLP

Federal Banking Agencies Open a Pathway to the Provision of Banking Services to Hemp-Related Businesses

White & Case LLP on

On December 3, 2019, in a rare public statement regarding the provision of banking services to cannabis- or hemp-related businesses, the Federal Banking Agencies, including the Board of Governors of the Federal Reserve...more

Ballard Spahr LLP

FinCEN Advisory Highlights Money Laundering Risks Related to Fentanyl Trafficking

Ballard Spahr LLP on

On August 21, 2019, FinCEN issued an advisory (the “Advisory”) alerting financial institutions to various financial schemes and mechanisms employed by fentanyl and synthetic opioid traffickers to facilitate the illegal...more

Foodman CPAs & Advisors

If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)

FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more

WilmerHale

Developments in the Marijuana Industry and the Implications for Financial Institutions

WilmerHale on

The myriad—and conflicting—state, federal and international laws governing the burgeoning marijuana industry have created a complicated legal landscape for financial institutions. In the United States, most states have...more

Foodman CPAs & Advisors

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

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

K2 Integrity

Is Your AML Program Up to the Task?

K2 Integrity on

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

Ballard Spahr LLP

Congress Proposes National Directory of Beneficial Owners of Legal Entities

Ballard Spahr LLP on

Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), currently in committee in the Senate.  The CTIFA proposes the most substantial overhaul to the Bank Secrecy Act (“BSA”) since...more

The Volkov Law Group

The Need for Anti-Money Laundering Regulatory Reform

The Volkov Law Group on

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

Robinson+Cole Data Privacy + Security Insider

U.S. Treasury Warns Financial Institutions of Venezuelan Corruption and Money Laundering

The Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury issued an advisory on September 20 warning U.S. financial institutions of “money laundering schemes used by corrupt Venezuelan...more

Ballard Spahr LLP

The New Paradigm: Proposed Reforms of the AML/CFT Regime by The Clearing House

Ballard Spahr LLP on

Today we are very pleased to welcome guest blogger Greg Baer, who will address a series of significant issues posed by a detailed paper published by The Clearing House, a banking association and payments company that is owned...more

Carlton Fields

Banks to Broaden Reporting of Suspicious Cyber Activity; Regulators Propose “Enhanced” Cybersecurity Standards

Carlton Fields on

The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more

Bradley Arant Boult Cummings LLP

Don’t Roll the Dice: FinCEN Assesses Significant Penalties on Regulated Entity for Failing to Implement a Comprehensive AML...

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) imposed a civil money penalty of $12 million against a Nevada based casino, CG Technology, L.P. (CGT) for alleged violations of the Bank Secrecy Act...more

Foodman CPAs & Advisors

De-Risking 101

Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Proskauer - Corporate Defense and Disputes

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

The Volkov Law Group

Rolling the Dice: Casinos, FinCEN and AML Compliance

The Volkov Law Group on

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML...more

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