News & Analysis as of

U.S. Treasury Enforcement Actions FinCEN

Foley & Lardner LLP

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions to Counter Cartel-Linked Fentanyl Trade

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On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...more

Lowenstein Sandler LLP

[Webinar] Targeted: How FinCEN's Fentanyl Fight Is Reshaping U.S.–Mexico Financial Compliance - August 7th, 11:00 am - 12:00 pm ET

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Join Lowenstein Sandler and Santamarina + Steta for a timely webinar exploring the legal and compliance implications of recent U.S. Treasury actions under the FEND Off Fentanyl Act. The session, featuring Lowenstein's Robert...more

Morrison & Foerster LLP

The Anti-Money Laundering Quarterly - July 2025

Designed for busy in-house counsel and compliance professionals, this newsletter summarizes some of the most important domestic and international Anti-Money Laundering (AML) regulatory and enforcement developments from the...more

Hogan Lovells

UPDATE #2: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed until September 4

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U.S. financial institutions that conduct funds transfers with the designated Mexican institutions have until 4 September to implement compliance procedures. Transfers of funds involving these designated Mexican institutions...more

Morrison & Foerster LLP

FinCEN Targets Three Mexico-Based Financial Institutions with Sanctions Under New Authority to Address Money Laundering Associated...

On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more

Bradley Arant Boult Cummings LLP

FinCEN’s Groundbreaking 2313a Orders: What U.S. Banks Need to Know About the Crackdown on Mexican Cartel-Linked Financial...

In a historic move that signals a new era in the fight against illicit opioid trafficking and money laundering, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued its first-ever...more

Ballard Spahr LLP

FinCEN Designates Three Mexican Financial Institutions as Primary Money Laundering Concerns Linked to Opioid Trafficking

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On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued three orders designating CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. (collectively,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Treasury Targets Mexican Financial Institutions Linked to Cartels Using New Fentanyl Sanctions Authority

On June 25, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying three Mexican financial institutions as being of primary money laundering concern in connection with...more

Snell & Wilmer

FinCEN Invokes New 2313a Authority Against Three Mexican Financial Institutions

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On June 25, 2025, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued unprecedented orders under the newly enacted 21 U.S.C. § 2313a authority, targeting three Mexico-based financial institutions:...more

Hogan Lovells

UPDATE: Effective date regarding FinCEN’s new Section 2313a Orders against three Mexican financial institutions

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U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions have until 21 July to implement compliance procedures. Transfers of funds involving these designated Mexican...more

Lowenstein Sandler LLP

Three Banks Targeted by FinCEN in FEND Off Fentanyl Act Actions: What to Know

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On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more

Hogan Lovells

FinCEN invokes new Section 2313a authority against three Mexican financial institutions: The who, what, when, where, why, and...

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The orders represent the first use of new authorities by FinCEN. U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions will be subject to significant compliance obligations,...more

Ballard Spahr LLP

FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

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In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more

Blank Rome LLP

Navigating New Compliance Challenges for Financial Institutions and Payment Processors: The U.S. Treasury’s Enhanced Terrorist...

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In a significant move to combat illicit financial activities focused on cartels, the U.S. government has intensified its scrutiny of cross-border payments, particularly those linked to Mexico. This development follows the...more

Eversheds Sutherland (US) LLP

FinCEN Southwest border GTO challenged by Texas trade group

On April 1, 2025, the Texas Association for Money Service Businesses filed a lawsuit in San Antonio federal court challenging the recent Geographic Targeting Order (GTO) applicable to money services businesses (MSBs) located...more

Morrison & Foerster LLP

The New CTA: Calling Foreign Reporting Companies Only

Since early December of last year, the CTA has been in a state of flux. As we recently reported, FinCEN announced it would delay the reporting deadline for most companies to March 21, 2025, and that it would provide any...more

Brooks Pierce

Corporate Transparency Act: FinCEN and the Treasury Announce Nonenforcement for Domestic Reporting Companies

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Following announcements from the Financial Crimes Enforcement Network (“FinCEN”) on February 27, 2025, and the United States Department of the Treasury (the “Treasury”) on March 2, 2025, it would appear that beneficial...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels - UPDATED 3/18/25

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

Foster Garvey PC

The Corporate Transparency Act May Be on Life Support, But It Is Not Dead

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I was hoping to take a short breather from covering the Corporate Transparency Act (“CTA”). However, I am getting several inquiries from attorneys and business owners, asking if they have missed anything with respect to the...more

Ward and Smith, P.A.

Corporate Transparency Act Enforcement Suspended Once Again!

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In a press release, Treasury officials confirmed they would not impose fines on U.S. citizens or domestic reporting companies, effectively pausing the reporting obligations for the time being.  Under the original CTA...more

Buchalter

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

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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

Agencies Ease Crypto Scrutiny as White House Advances its Digital Assets Policy

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Actions come as Trump Administration hosts digital asset summit, creates bitcoin reserve, and pushes stablecoin legislation - Recent actions by federal agencies and the White House could herald a sea change in US policy...more

Robinson & Cole LLP

Legal Update: New Rulemaking Announced: Treasury Department Suspends Reporting, Enforcement and Fines under the Corporate...

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How Did We Get Here? The Corporate Transparency Act (CTA) went into effect on January 1, 2024, and was enacted as part of the Anti-Money Laundering Act of 2020....more

Verrill

Indefinite Suspension of CTA Filing Obligations (For Now)

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On March 2, 2025 the U.S. Treasury Department laid waste to about a million law firm postings about the Corporate Transparency Act, announcing that Treasury now intends to propose fundamental changes to the CTA Rule and that...more

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