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Money Laundering U.S. Treasury Financial Crimes

Ankura

Toothless: How Proposed Changes to the Corporate Transparency Act Diminish its Efficacy

Ankura on

17 Back in 2021, the U.S. Government passed the Corporate Transparency Act (CTA), which was an effort to improve upon the Bank Secrecy Act (BSA) and bolster the nation’s defenses against Money Laundering and Terrorist...more

Snell & Wilmer

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

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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

Morrison & Foerster LLP

The Anti-Money Laundering Quarterly - July 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

Morrison & Foerster LLP

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

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

Bradley Arant Boult Cummings LLP

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

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

Ballard Spahr LLP

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

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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

Hogan Lovells

UPDATE: Effective date regarding FinCEN’s new Section 2313a Orders against three Mexican financial institutions

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U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions have until 21 July to implement compliance procedures. Transfers of funds involving these designated Mexican...more

Bradley Arant Boult Cummings LLP

How the Trump Administration’s War on Cartels Will Reshape the Financial Sector

On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more

Ballard Spahr LLP

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

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We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

Orrick, Herrington & Sutcliffe LLP

FinCEN requires several southwest counties to report cash transactions over $200

On March 11, FinCEN issued a Geographic Targeting Order (GTO) to combat “illicit activities and money laundering of Mexico-based cartels” along the U.S. southwest border. The order requires money service businesses in select...more

Buchalter

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

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On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

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On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Troutman Pepper Locke

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

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As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Latham & Watkins LLP

FCA Findings on Firms’ Treatment of Politically Exposed Persons

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Regulator finds that firms could improve how they conduct anti-money laundering checks when dealing with UK PEPs. ...more

Ballard Spahr LLP

Treasury Issues Request for Information on Use of AI in Financial Services

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The U.S. Department of the Treasury (“Treasury”) has released a Request for Information on the Uses, Opportunities, and Risks of Artificial Intelligence (“AI”) in the Financial Services Sector (“RFI”).  Written comments are...more

Ballard Spahr LLP

Treasury Asks the Eleventh Circuit to Uphold the CTA and Congressional Authority

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We previously blogged on the lawsuit filed by the National Small Business Association (“NSBA”) and one of its individual members, which sought to challenge the constitutionality of the Corporate Transparency Act (“CTA”). Most...more

The Volkov Law Group

Sterling Bank’s ex-General Counsel hit with OCC Cease-and-Desist over Longstanding BSA/AML Shortcomings

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The Treasury Department’s Office of the Comptroller of the Currency (“OCC”) has taken action against the former General Counsel of Michigan-based Sterling Bank and Trust in the agency’s latest action against an individual...more

Fox Rothschild LLP

NY State's New Transparency Law Targets LLCs

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New York is poised to impose its own set of disclosure requirements on certain businesses later this year with a new law that mirrors the federal Corporate Transparency Act (CTA). In December, Gov. Kathy Hochul signed into...more

Hendershot Cowart P.C.

Small Business Owners: New Federal Reporting Requirements Start January 1

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Beginning January 1, 2024, most small businesses in the United States will have to report information about the people who own and control the business to the federal government. This new reporting rule was established by...more

Cozen O'Connor

Important Information Regarding U.S. Corporate Transparency Act / 美国企业透明法重要信息

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A new regulation under the federal Corporate Transparency Act (CTA) that, for the first time, will require disclosure of information about all U.S. formed corporations, limited liability companies, and limited partnerships...more

Ballard Spahr LLP

Hamas, Terrorist Financing, and Cryptocurrency

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The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more

Wilson Sonsini Goodrich & Rosati

FinCEN Releases Proposed Rule Designating CVC Mixing as a “Primary Money Laundering Concern”

On October 23, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (proposed rule) addressing “mixing transactions” that involve convertible...more

Troutman Pepper Locke

FinCEN Issues Alert for Financial Institutions on Red Flags for “Pig Butchering” Schemes

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On September 8, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) issued an alert warning financial institutions to be vigilant against a prominent virtual currency investment scam called...more

Dickinson Wright

Corporate Transparency Act Compliance Date Is Approaching Quickly

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Although the Corporate Transparency Act (CTA”) was adopted in 2021,  implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”)  established regulations. The deadline,...more

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