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
On February 27, FinCEN issued an alert to financial institutions on the nationwide surge in check fraud schemes targeting the U.S. mail. Mail theft-related check fraud, FinCEN explained, generally relates to the fraudulent...more
On January 13, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling along the...more
On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more
As green states continue to grow, intentional or unintentional exposure to Marijuana Related Business (“MRB”) customers for financial institutions and broker-dealers is an inevitability. Whether your business has decided to...more
This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more
Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more
The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more
On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more
On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more
FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...more
The Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would require registered investment advisers to establish anti-money laundering programs and file suspicious activity reports with...more
On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury, released proposed rules that would extend anti-money laundering (AML) requirements to investment advisers...more
On Tuesday, the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would require SEC-registered investment advisers, including private equity and hedge funds, to comply...more
FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML...more
Executives of regulated entities often lament that fulfilling compliance obligations interferes with their ability to operate their business. However, an extensive (and extended) regulator investigation with the potential for...more
For the second time in nine months, Financial Crimes Enforcement Network (FinCEN) Director Jennifer Shasky Calvery has publicly addressed FinCEN's increasing concerns regarding casino compliance with the Bank Secrecy Act...more