News & Analysis as of

Suspicious Activity Reports (SARs) Reporting Requirements

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

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

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

Friling Law

Legal Guidance for Financial Integrity and Whistleblower Protection

Friling Law on

Over the past few years, whistleblowers have become a driving force in uncovering financial misconduct in the U.S. Individuals may report illicit financial activity, including money laundering, sanctions evasion, fraud, and...more

Lowenstein Sandler LLP

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

Lowenstein Sandler LLP on

On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

White & Case LLP

“Unsubstantiated” suspicious transaction reports

White & Case LLP on

While financial institutions, on the one hand, are in the process of implementing and preparing to apply the fundamental amendments and changes that will take place in upcoming years by the EU AML Package—entering into force...more

K&L Gates LLP

The Latest OFSI Property and Related Services Threat Assessment

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The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has published a report detailing suspected breaches of UK financial sanctions involving UK property and related services firms since February 2022 and...more

Mayer Brown

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

Mayer Brown on

On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

A&O Shearman

UK Financial Intelligence Unit SARS report published

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The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...more

K&L Gates LLP

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

K&L Gates LLP on

On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more

Alston & Bird

FinCEN Issues Geographic Targeting Order for U.S. Southwestern Border

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Our Financial Services and White Collar, Government & Internal Investigations Groups unpack the Financial Crimes Enforcement Network’s new geographic targeting order aimed at combatting money laundering and other illegal...more

Buchalter

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

Buchalter on

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

DLA Piper

FinCEN’s Geographic Targeting Order Increases Reporting Obligations for Money Services Businesses Located Near the United...

DLA Piper on

On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more

K&L Gates LLP

Lessons From 2024 Anti-Money Laundering Enforcement Actions

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In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more

Carlton Fields

Deadline Approaches for RIAs to Adopt AML Programs CIP Requirements Remain in Limbo

Carlton Fields on

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). For...more

K2 Integrity

Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now?

K2 Integrity on

On 15 January 2025, K2 Integrity hosted a webinar that featured Justina Rousseau, senior managing director at K2 Integrity; Aseel Rabie, counsel at Debevoise & Plimpton LLP; and Sarah Runge, executive managing director at K2...more

Sheppard Mullin Richter & Hampton LLP

FDIC Enforcement Spotlights Deficiencies in Kansas Bank’s Anti-Money Laundering Program

On December 27, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a notice of assessment of a civil money penalty against a Kansas-based bank. The action, originally brought in November, imposed a $20.4 million...more

Davis Wright Tremaine LLP

FinCEN Warns of Criminal Use of Deepfake Technology to Circumvent Controls

Generative artificial intelligence (AI) holds tremendous promise for financial institutions and their customers. But that promise comes with potential peril, as highlighted in a recent alert issued by the U.S. Treasury...more

Ballard Spahr LLP

FinCEN Reports Check Fraud Amounting to $688 Million Over Six Month Period

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The Financial Crimes Enforcement Network (“FinCEN”) issued last month an in-depth report on check fraud stemming from mail theft (“Report”).  This is a pernicious and expanding problem.  The Report follows upon a joint alert...more

Foodman CPAs & Advisors

Residential Real Estate and FinCEN

FinCEN seeks to safeguard residential real estate as evidenced by the issuance of the Final Residential Real Estate Rule issued 8/28/24 and taking effect on 12/1/25. The Final Rule requires “certain” industry professionals...more

Jones Day

Investment Advisers Subject to AML and SARs Requirements

Jones Day on

The Situation: The Financial Crimes Enforcement Network ("FinCEN") has adopted a rule that subjects certain investment advisers to anti-money laundering/countering the financing of terrorism program ("AML") requirements...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

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On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

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