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Regulatory Reform Financial Crimes Money Services Business

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

Orrick, Herrington & Sutcliffe LLP

Texas expands its banking commissioner’s powers into money services

On June 20, the governor of Texas signed into law HB 3805, expanding the Texas Department of Banking’s (TDB) enforcement powers over money services businesses. As stated in the state’s bill analysis, the TDB previously had...more

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