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National Security Anti-Money Laundering

Mayer Brown

FinCEN's First Strike: New Section 311 Powers Target Mexican Financial Institutions Under FEND Off Fentanyl Act

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In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more

Morrison & Foerster LLP

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

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

Mayer Brown

FinCEN Designates Three Mexican Financial Institutions Under New Section 311 Authority: First Use of Expanded Powers Under FEND...

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On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more

A&O Shearman

FATF report identifies vulnerabilities in counter proliferation financing

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The Financial Action Task Force (FATF) has published a report and accompanying press release, highlighting significant vulnerabilities in the global financial system's ability to combat proliferation financing (PF) and...more

Troutman Pepper Locke

The GENIUS Act: What Is It and What’s Next?

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On June 17, the U.S. Senate voted 68-30 to pass S.1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act (the Act). This represents a landmark effort by the U.S. Congress to...more

Orrick, Herrington & Sutcliffe LLP

Senators pen bipartisan letter arguing rescission of Treasury rule

On May 27, Sens. Sheldon Whitehouse (D-RI) and Charles Grassley (R-IA) wrote to the Treasury encouraging recission of the interim final rule requiring “foreign reporting companies,” but not domestic entities or U.S. citizens,...more

Holland & Knight LLP

Mexico Creates Specialized General Agency on Criminal Organizations

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Mexico's Official Gazette of the Federation (Diario Oficial de la Federación) published a decree to reform and add provisions to the Internal Regulations of the Ministry of Finance and Public Credit (SHCP), establishing the...more

Troutman Pepper Locke

The GENIUS Act Advances in the Senate

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The U.S. Senate’s proposal to regulate stablecoins, known as the GENIUS Act, has successfully cleared a significant procedural hurdle, moving closer to a full floor debate. On May 19, lawmakers voted to invoke cloture on the...more

DLA Piper

Cartels, China, and Fentanyl-Related Illicit Finance

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FinCEN report reveals threat patterns and trends for financial institutions to monitor - The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury (Treasury) published a Financial Trend Analysis...more

Sheppard Mullin Richter & Hampton LLP

Federal Crypto Ownership: Compliance Implications of the Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile

Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile, federal agencies and market participants may begin to grapple with the operational and compliance...more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

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As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Morgan Lewis

US Designation of Cartels as Terrorist Organizations Increases Risk of Doing Business in Mexico

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Recent US government actions indicate a possible increase in US financial crimes investigations and enforcement targeting drug cartels and transnational criminal organizations in Latin America....more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...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

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels - UPDATED 3/18/25

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

Paul Hastings LLP

The Bybit Hack of 2025 — Potential Implications

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On February 21, 2025, Dubai-based Bybit, one of the world’s leading cryptocurrency exchanges, suffered a massive security breach, resulting in the loss of approximately $1.5 billion in Ethereum (ETH). The incident, which is...more

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

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Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more

Faegre Drinker Biddle & Reath LLP

The Wallet Inspectors: The DPRK’s Sophisticated Campaign to Steal Cryptocurrency and How to Protect Yourself

On February 21, 2025, Bybit, one of the world’s largest cryptocurrency exchanges, suffered a cyberattack resulting in the theft of approximately $1.5 billion in Ethereum tokens.  This attack marked a new pinnacle in the...more

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

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The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

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On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

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Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more

Wilson Sonsini Goodrich & Rosati

The Corporate Transparency Act is Back On–Again!

On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted the federal government’s motion for a stay pending appeal and lifted the nationwide preliminary injunction in Smith, et al. v. U.S....more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Holland & Knight LLP

Trump Administration Announces Designation of International Cartels

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U.S. President Donald Trump issued Executive Order 14157 (the EO) on Jan. 20, 2025, calling for the designation of drug cartels and other foreign organizations as foreign terrorist organizations (FTOs) or specially designated...more

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