News & Analysis as of

U.S. Treasury Financial Institutions

Orrick, Herrington & Sutcliffe LLP

Treasury seeks public input on innovative methods to detect illicit digital asset activity

On August 18, the Treasury issued a request for public comment on technologies and strategies to help financial institutions identify and mitigate illicit financial risks involving digital assets. The notice solicited...more

Cadwalader, Wickersham & Taft LLP

New Lessons in Regulation, August 2025 - FinCEN Extends Effectiveness Date of Orders Targeting CIBanco, Intercam, and Vector until...

Parties have an additional six weeks to prepare for the impact of FinCEN’s June 25, 2025 orders targeting three Mexican financial institutions. On August 19, 2025, FinCEN extended the effectiveness date of three orders...more

Sheppard Mullin Richter & Hampton LLP

Trump Signs Executive Order on Debanking

On August 7, President Trump signed an Executive Order directing federal banking regulators to prevent financial institutions and financial service providers from denying or restricting financial services and products based...more

Mayer Brown

President Trump Signs Debanking Executive Order

Mayer Brown on

On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for All Americans” (the “Order”). The Order announces the Administration’s plan to address the exclusion of certain...more

Amundsen Davis LLC

President Trump Takes Action to Ensure Fair Banking for All Americans

Amundsen Davis LLC on

On August 7, 2025, President Donald J. Trump signed an executive order titled “Guaranteeing Fair Banking for All Americans.” The order asserts that financial institutions have restricted the access of individuals and...more

Buchalter

New Federal Regulatory Regime Provides Foundation for Financial Institutions to be Stablecoin Issuers and Accept Cryptocurrency...

Buchalter on

There has been a flurry of activity in Congress and the White House to liberalize and encourage the development of cryptocurrency as a payment method, including creating a legal regime for depository and non-depository...more

Haynes Boone

World Bank Reconsiders Nuclear Finance

Haynes Boone on

Under mounting pressure from advocates and stakeholders—most prominently the United States government—the World Bank recently rescinded its longstanding ban on financing nuclear power projects and announced its plan to...more

Hogan Lovells

Crypto week in the U.S. House of Representatives: The GENIUS Act and the push for regulatory clarity

Hogan Lovells on

Following the week of July 14, 2025 – labelled as “Crypto Week” by the U.S. House of Representatives – the United States has witnessed significant developments in its digital asset regulatory framework, including the signing...more

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

Lowenstein Sandler LLP on

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

BakerHostetler

A New Era for the Stablecoin Industry: The GENIUS Act

BakerHostetler on

On Friday, July 18, President Donald J. Trump signed into law historic legislation to establish a legal framework for the payment stablecoin industry in the United States, S.1582, the Guiding and Establishing National...more

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

Ballard Spahr LLP on

We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Polsinelli

Blockchain+ Bi-Weekly; Crypto Legislation Breaks Through: GENIUS Act Signed, CLARITY Advances and Other Key Web3 Legal Highlights:...

Polsinelli on

In a historic week for digital assets, the United States has officially enacted its first federal crypto legislation with the GENIUS Act signed into law on July 18, 2025. Passed after the longest House vote in history, this...more

Fenwick & West LLP

Congress Enacts Comprehensive Stablecoin Legislation: Key Provisions and Implications of the GENIUS Act

Fenwick & West LLP on

On July 18, President Donald Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), creating the first federal framework for U.S. dollar stablecoins. ...more

Hone Maxwell

Understanding FATCA and Its Impact on Foreign Financial Institutions: Why Finding Financial Services as an American Abroad Can Be...

Hone Maxwell on

As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more

Barnea Jaffa Lande & Co.

Who Bears the Risk of Violating Personal Sanctions?

When US President Donald Trump took office, it seemed the question of personal sanctions against extremist right-wingers in Israel was off the table. Indeed, in one of his first decisions, Trump lifted the sanctions imposed...more

Davis Wright Tremaine LLP

Rethinking Bank Leverage and Capital Requirements in 2025

On July 10, 2025, the federal banking agencies published a proposed rule to change the enhanced supplementary leverage ratio (eSLR) for U.S. global systemically important bank holding companies (GSIBs) and their subsidiary...more

Venable LLP

Congress Passes The GENIUS Act: Key Impacts for the Payments Industry and Financial Institutions

Venable LLP on

In a major step toward establishing regulatory clarity for digital assets, the House of Representatives passed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act on Thursday, July 17, alongside...more

Sheppard Mullin Richter & Hampton LLP

Senate Confirms Jonathan Gould as Comptroller of the Currency

On July 10, 2025, the U.S. Senate confirmed Jonathan Gould as Comptroller of the Currency in a 50–45 vote. Gould will serve a five-year term and returns to the OCC, where he previously served as Chief Counsel and Senior...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

Orrick, Herrington & Sutcliffe LLP

OCC’s new comptroller of the currency is Jonathan Gould

On July 15, the OCC announced that Jonathan V. Gould has taken office as the 32nd comptroller of the currency, following his nomination by President Donald J. Trump on February 11 and confirmation by the U.S. Senate on July...more

Hogan Lovells

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

Hogan Lovells on

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

McGlinchey Stafford

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on

In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...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

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