News & Analysis as of August 14, 2025

FinCEN › U.S. Treasury

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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 Targets Three Mexican Financial Institutions for Fentanyl Trafficking

Patomak Global Partners on 8/13/2025

The Trump Administration has repeatedly signaled its prioritization of targeting traffickers of synthetic opioids, especially fentanyl. On January 20, 2025, President Trump signed an Executive Order “creating a process by...more

FinCEN Rule Targets All-Cash Residential Real Estate Deals Involving Entities & Trusts

Adams & Reese on 8/13/2025

A new nationwide anti-money laundering rule introduces mandatory reporting to the U.S. Department of Treasury’s FinCEN (Financial Crimes Enforcement Network) for specific all-cash residential real estate transactions...more

U.S. Senate introduces Act to apply AML/BSA laws to art dealers and auction houses

Ballard Spahr LLP on 8/6/2025

On July 23, 2025, Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Bill Cassidy (R-LA), Andy Kim (D-NJ), and David McCormick (R-PA), introduced the federal Art Market Integrity Act (the...more

New Federal Regulatory Regime Provides Foundation for Financial Institutions to be Stablecoin Issuers and Accept Cryptocurrency...

Buchalter on 8/5/2025

There has been a flurry of activity in Congress and the White House to liberalize and encourage the development of cryptocurrency as a payment method, including creating a legal regime for depository and non-depository...more

Treasury Postpones Effective Date of Investment Adviser AML Rule

ArentFox Schiff on 8/4/2025

On July 21, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a two-year postponement of the Anti-Money Laundering (AML)/Countering the Financing of Terrorism (CFT) Program and...more

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

BCLP on 7/29/2025

FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions to Counter Cartel-Linked Fentanyl Trade

Foley & Lardner LLP on 7/29/2025

On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...more

[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

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

Ballard Spahr LLP on 7/25/2025

We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

FinCEN Postpones New AML Rule for Investment Advisers

Latham & Watkins LLP on 7/25/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on 7/24/2025

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

Treasury to Delay Investment Adviser AML Rule to 2028, Announces Intent to Reconsider AML and CIP Rules

Proskauer Rose LLP on 7/23/2025

On July 21, 2025, the Department of the Treasury announced a two-year postponement of the much-anticipated anti-money laundering (AML) rule, adopted by Treasury’s Financial Crimes Enforcement Network (FinCEN) in 2024,...more

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

Morrison & Foerster LLP on 7/23/2025

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on 7/23/2025

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Passage of the GENIUS Act: A Turning Point in Stablecoin and Digital Asset Regulation

Cozen O'Connor on 7/22/2025

President Donald J. Trump has signed into law the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins of 2025 or the GENIUS Act of 2025), establishing the first comprehensive federal framework for...more

The Anti-Money Laundering Quarterly - July 2025

Morrison & Foerster LLP on 7/17/2025

Designed for busy in-house counsel and compliance professionals, this newsletter summarizes some of the most important domestic and international Anti-Money Laundering (AML) regulatory and enforcement developments from the...more

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

Robinson Bradshaw on 7/15/2025

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

The United States Terminates Countrywide Syria Sanctions and Is Working Towards Lifting Additional Trade Restrictions

K2 Integrity on 7/15/2025

Building on prior relief of sanctions and other restrictive trade measures earlier this year (as described in K2 Integrity alerts dated 15 May and 09 June 2025), on 30 June 2025, U.S. President Donald Trump issued a new...more

UPDATE #2: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed until September 4

Hogan Lovells on 7/11/2025

U.S. financial institutions that conduct funds transfers with the designated Mexican institutions have until 4 September to implement compliance procedures. Transfers of funds involving these designated Mexican institutions...more

No Need to Report That Your Domestic Entity is Now Exempt from BOI Reporting Requirements

Verrill on 7/10/2025

Through an Interim Final Rule that became effective March 26, 2025 (the “IFR”), the U.S. Treasury Department took action to exclude all U.S.-formed entities from the BOI[1] reporting regime under the Corporate Transparency...more

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on 7/10/2025

In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

Morrison & Foerster LLP on 7/8/2025

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

FinCEN Targets Three Mexico-Based Financial Institutions with Sanctions Under New Authority to Address Money Laundering Associated...

Morrison & Foerster LLP on 7/8/2025

On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more

FinCEN’s Groundbreaking 2313a Orders: What U.S. Banks Need to Know About the Crackdown on Mexican Cartel-Linked Financial...

Bradley Arant Boult Cummings LLP on 7/3/2025

In a historic move that signals a new era in the fight against illicit opioid trafficking and money laundering, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued its first-ever...more

FinCEN Designates Three Mexican Financial Institutions as Primary Money Laundering Concerns Linked to Opioid Trafficking

Ballard Spahr LLP on 7/3/2025

On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued three orders designating CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. (collectively,...more

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FinCEN › U.S. Treasury

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