News & Analysis as of

U.S. Treasury AML/CFT

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

Skadden, Arps, Slate, Meagher & Flom LLP

US Establishes First Federal Regulatory Framework for Stablecoins: The GENIUS Act Passes Congress and Awaits President Trump’s...

- What is new: The U.S. Congress has passed the GENIUS Act, establishing the first federal regulatory framework for payment stablecoins, addressing consumer protection, financial stability and AML compliance. - Why it...more

Robinson Bradshaw

Application of New Anti-Money Laundering Regulations to Advisers to Private Funds

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On Sept. 4, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a final rule imposing new anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements on...more

Secretariat

Guardians of Finance Integrity, How the NY Fed’s Oversight in Iraq and Libya Could Hold a Blueprint for Post-Conflict...

Secretariat on

The Federal Reserve Bank of New York (FRBNY) has cemented its role as a global financial watchdog, using its influence to safeguard the integrity of the U.S. dollar and the broader international financial system. Recent...more

Arnall Golden Gregory LLP

OFAC and KoFIU Sanctions Compliance for Financial Technologies Companies

As financial technologies companies expand operations across borders, understanding the sanctions regimes of both the United States and South Korea becomes essential. The U.S. Treasury Department’s Office of Foreign Assets...more

Cozen O'Connor

Corporate Transparency Act Compliance

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The federal Corporate Transparency Act (CTA) requires disclosure of information about all corporations, limited liability companies and limited partnerships (unless exempt), and personal information about their beneficial...more

Hahn Loeser & Parks LLP

90 Days and Counting for the Initial CTA Deadline

Time is running out. We are now in the 4th quarter of 2024 and despite legal challenges and proposed actions in the legislature, the year-end Corporate Transparency Act (“CTA”) reporting deadline remains incumbent upon...more

Seward & Kissel LLP

Department of the Treasury Releases New AML/CFT Rule for Investment Advisers

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Who may be interested: Investment Advisers - Quick Take: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule subjecting certain registered investment advisers (RIAs) and...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

Ballard Spahr LLP

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

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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

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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

Morrison & Foerster LLP

FinCEN & the SEC: Will the Real RIA and ERA Customers Please Stand Up?

On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more

Troutman Pepper Locke

FinCEN Proposes Rule to Strengthen AML/CFT Programs

Troutman Pepper Locke on

On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Ballard Spahr LLP

Treasury Issues RFI on Use of AI in Financial Services

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After several years of monitoring and reporting on artificial intelligence (AI) in financial services, the U.S. Department of Treasury (Treasury) has embarked on initial rulemaking efforts and issued a request for information...more

Ballard Spahr LLP

Treasury Issues Request for Information on Use of AI in Financial Services

Ballard Spahr LLP on

The U.S. Department of the Treasury (“Treasury”) has released a Request for Information on the Uses, Opportunities, and Risks of Artificial Intelligence (“AI”) in the Financial Services Sector (“RFI”).  Written comments are...more

Eversheds Sutherland (US) LLP

FinCEN and SEC propose Customer Identification Program requirements for investment advisers

Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

Ballard Spahr LLP

Treasury Issues Broad National Strategy for Combatting Illicit Financing

Ballard Spahr LLP on

Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more

Akin Gump Strauss Hauer & Feld LLP

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

In February 2024, the U.S. Department of the Treasury issued its 2024 Investment Adviser Risk Assessment, which explains that there are “several illicit finance threats involving investment advisers,” including that...more

Paul Hastings LLP

Daily Financial Regulation Update -- Friday, April 5, 2024

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April 4, 2024- Secretary of the Treasury Janet L. Yellen held a roundtable discussion with representatives from the American, European, and Japanese business communities and other experts to discuss business conditions in...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 3

Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

ArentFox Schiff on

On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

Foodman CPAs & Advisors

Acciones Clave GAFI Febrero 2024

El 02/23/24, el Grupo de Acción Financiera Internacional (GAFI o “FATF”), una entidad intergubernamental independiente que desarrolla políticas para la protección de nuestro sistema financiero global contra el lavado de...more

Foodman CPAs & Advisors

FATF Key Actions February 2024

On 2/23/24, the Financial Action Task Force (FATF), an independent inter-governmental entity that develops policies for protection of our global financial system from money laundering, terrorist financing and financing of...more

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more

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