News & Analysis as of July 30, 2025

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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 -

US Corporate Governance — 2025 Midyear Review

Herbert Smith Freehills Kramer on 7/8/2025

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

Gordon Rees Scully Mansukhani on 5/22/2025

The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more

Weekly Blockchain Blog - May 2025

BakerHostetler on 5/5/2025

U.S. Companies Continue Stablecoin Payment Integrations, Product Launches - According to a recent press release, a major multinational payment card services company has announced several new programs to support global...more

Daily Financial Regulation Update -- Tuesday, April 15, 2025

Paul Hastings LLP on 4/15/2025

April 11, 2025- The Credit Access and Inclusion Act was introduced to expand credit access for millions of Americans with limited or non-existent credit histories. April 14, 2025- Federal Reserve Board Governor...more

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – February 2025

Troutman Pepper Locke on 2/5/2025

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Crypto Executive Order: A New Era for Digital Assets

Paul Hastings LLP on 1/31/2025

President Trump’s crypto executive order (the Crypto Executive Order) was a first step in the Trump Administration’s articulation of a policy on promoting the lawful use of blockchain technology. It remains to be seen whether...more

Focus on Fintech – Q3 2024

Wilson Sonsini Goodrich & Rosati on 12/17/2024

In this issue of Wilson Sonsini's Focus on Fintech, our attorneys discuss updates and developments from federal regulators, including those related to bank-fintech partnerships, cryptocurrency and virtual currency updates,...more

Securities & Corporate Governance Q4 2024 Quarterly Newsletter

Morris, Manning & Martin, LLP on 12/13/2024

Morris, Manning & Martin, LLP’s Securities & Corporate Governance Quarterly Newsletter is designed to update public and private company clients on recent developments in federal securities laws and corporate governance...more

Enforcement News: Broker-Dealers Settle Charges for Filing Deficient SARs

Freiberger Haber LLP on 12/3/2024

The Bank Secrecy Act (“BSA”) and implementing regulations promulgated by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) require that broker-dealers file a suspicious activity report (SAR”) with...more

Navigating the Dark Side of Crypto: Crime, Compliance, and Consumer Protection – The Crypto Exchange Podcast

Troutman Pepper Locke on 11/12/2024

In the latest episode of The Crypto Exchange, host Ethan Ostroff is joined by colleagues Brett Broczkowski and Mike Lowe to discuss the intersection of crime and cryptocurrency, with a focus on the challenges financial...more

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

ArentFox Schiff on 11/4/2024

On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on 10/24/2024

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

FUNDamentals: Navigating FinCEN’s ‎New AML Regulations for Investment ‎Advisers

Troutman Pepper Locke on 10/10/2024

On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Rule”) that amends the definition of “financial institution” under the Bank Secrecy Act...more

FinCEN Issues Final Rule Expanding Anti-Money Laundering/ Countering the Financing of Terrorism Requirements for Investment...

King & Spalding on 9/10/2024

On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

Holland & Knight LLP on 9/6/2024

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more

Investment Advisers Prepare: The BSA is Here

Lowenstein Sandler LLP on 9/3/2024

On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more

Off to the Races: DOJ Offers New Incentives for Whistleblowers and Companies to Report Misconduct

Paul Hastings LLP on 8/9/2024

Earlier this year, as described in a previous client alert, the Department of Justice (“DOJ”) Criminal Division announced a landmark pilot program to pay monetary awards to whistleblowers (the “Program”). At that time, Deputy...more

FinCEN Proposes Rule To Strengthen US Anti-Money Laundering and Countering the Financing of Terrorism Programs

Skadden, Arps, Slate, Meagher & Flom LLP on 7/17/2024

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule (the Proposed Rule) to implement certain aspects of the Anti-Money Laundering Act of 2020 (the AML Act), which updated the...more

FinCEN & the SEC: Will the Real RIA and ERA Customers Please Stand Up?

Morrison & Foerster LLP on 7/8/2024

On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

K&L Gates LLP on 6/27/2024

Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

AML/CFT Rules for Investment Advisers

K2 Integrity on 6/18/2024

On 12 June 2024, K2 Integrity and Schulte Roth & Zabel hosted a webinar discussing new regulatory obligations anticipated under proposed rules for investment advisers (IAs), timelines for finalization and compliance, and how...more

Request for Comments on FinCEN and SEC rule on CIP

King & Spalding on 5/24/2024

The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

Guidepost Solutions LLC on 5/24/2024

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

SEC, FinCEN Propose to Mandate Customer Identification Programs for Registered Investment Advisers, Exempt Reporting Advisers

Cooley LLP on 5/22/2024

On May 13, 2024, the US Securities and Exchange Commission (SEC) and the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly issued a notice of proposed rulemaking that would require investment...more

SEC and FinCEN Propose Rules to Impose Customer Identification Program Obligations on Certain Investment Advisers

BCLP on 5/21/2024

On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more

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