News & Analysis as of August 12, 2025

FinCEN

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A repository for the most well-read content on JD Supra at any given time, along with occasional roundups of popular content by specific topic. Also stop by for monthly recaps of hot articles for the previous... more +

Operation and Structure of the GENIUS Act of 2025 on Payment Stablecoins

Cadwalader, Wickersham & Taft LLP on 6/24/2025

The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more

Client Alert: The GENIUS Act: A Compliance Roadmap for Stablecoin Issuers in 2025

Whiteford on 6/3/2025

In April 2025, the Senate Banking Committee voted to advance the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, a landmark bill introduced by Senator Bill Hagerty to regulate the $180 billion...more

FINCEN Filings Terminated

Lasher Holzapfel Sperry & Ebberson PLLC on 3/11/2025

Per the U.S. Treasury Department announcement below, FinCEN is now dead except for some limited foreign entity reporting. Despite the many turbulent things happening in the U.S. government right now, this still came out of...more

Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule...

Weintraub Tobin on 3/7/2025

On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related...more

Congress Narrows in on Stablecoin Legislation: An Analysis of the STABLE and GENIUS Acts

Troutman Pepper Locke on 2/13/2025

The payment stablecoin (PS) legislative endgame is near. There is a clear imperative from the White House to prioritize stablecoin legislation and preserve the U.S. dollar as the world’s reserve currency. Both chambers of...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

What Is an “Effective AML/CFT Compliance Program”?

Perkins Coie on 8/23/2024

The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

FinCEN Proposes Rule to Enhance AML/CFT Programs Across Industries

Ballard Spahr LLP on 7/26/2024

FinCEN’s recent preliminary rulemaking aims to enhance and modernize regulations with requirements and priorities that affect a broad range of “financial institutions” across industries—but lacks concrete guidance on...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

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

Jenner & Block on 5/20/2024

In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more

FinCEN’s Anti-Money Laundering Regulations for Residential Real Estate Transfers

Falcon Rappaport & Berkman LLP on 2/23/2024

To crack down on money-laundering in the U.S. residential real estate market, the Financial Crimes Enforcement Network (“FinCEN”) has proposed new reporting requirements for certain real estate transactions. Specifically, the...more

The Wait Is Over: Corporate Transparency Act Takes Effect

Bradley Arant Boult Cummings LLP on 1/9/2024

The Corporate Transparency Act (CTA) and its requirements for privately held companies to report their beneficial ownership information went into effect on January 1, 2024. The CTA requires most corporations, limited...more

Federal Agencies Issue Access Rule to Beneficial Ownership Information Pursuant to the CTA

Troutman Pepper Locke on 12/27/2023

On December 21, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Financial Crimes Enforcement Network (FinCen), the National Credit Union Administration, along with...more

FinCEN Issues Final CTA BOI Access Rules, Heralded by YouTube Video

Ballard Spahr LLP on 12/22/2023

This week, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial ownership information (“BOI”)...more

Regulators Sharpen Focus on Anti-Money Laundering Expectations for Crypto Industry

Cadwalader, Wickersham & Taft LLP on 1/20/2023

U.S. regulators are signaling heightened expectations for anti-money laundering compliance within the crypto industry. Although FinCEN issued guidance in 2013 interpreting virtual currency “administrators” and “exchanges” as...more

Year-end Crypto Roundup — Five Key Concepts About the U.S. Government’s Recent Actions on Virtual Currency and Ransomware

Orrick, Herrington & Sutcliffe LLP on 12/30/2021

The innovative use of virtual currencies is hotter than ever, but so is a dark side of these instruments: their exploitation in ransomware schemes. This year, since January 2021, ransomware attacks have increased...more

Proposed Rules for Transactions with Unhosted Virtual Currency Wallets

K2 Integrity on 1/6/2021

On 18 December, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury announced highly anticipated and controversial new proposed requirements designed to mitigate illicit finance risks...more

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