News & Analysis as of

Suspicious Activity Reports (SARs) U.S. Treasury Money Laundering

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on

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

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

Holland & Knight LLP on

The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...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

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

Lowenstein Sandler LLP on

On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Ballard Spahr LLP

Three Members of Congress and U.S. Treasury Express Concerns that Florida Law Prohibiting Banks from Considering Customers’...

Ballard Spahr LLP on

As we previously blogged, a Florida law (Fla. Stat. § 655.0323, entitled “Unsafe and unsound practices”) which became effective July 1, 2024 prohibits federal and state depository institutions conducting business in the state...more

Troutman Pepper Locke

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

Troutman Pepper Locke on

As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on

On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Ballard Spahr LLP

Hamas, Terrorist Financing, and Cryptocurrency

Ballard Spahr LLP on

The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more

Holland & Knight LLP

FinCEN Announces National AML/CFT Policy Priorities

Holland & Knight LLP on

The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

Robinson+Cole Data Privacy + Security Insider

U.S. Treasury Warns Financial Institutions of Venezuelan Corruption and Money Laundering

The Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury issued an advisory on September 20 warning U.S. financial institutions of “money laundering schemes used by corrupt Venezuelan...more

Troutman Pepper

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

Troutman Pepper on

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

Stinson - Corporate & Securities Law Blog

FinCEN Proposes Extending Anti-Money Laundering Compliance Requirements to Investment Advisers

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

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