News & Analysis as of

U.S. Treasury FinCEN

BCLP

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

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FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

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

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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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

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

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

Proskauer Rose LLP

Treasury to Delay Investment Adviser AML Rule to 2028, Announces Intent to Reconsider AML and CIP Rules

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On July 21, 2025, the Department of the Treasury announced a two-year postponement of the much-anticipated anti-money laundering (AML) rule, adopted by Treasury’s Financial Crimes Enforcement Network (FinCEN) in 2024,...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

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

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On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Cozen O'Connor

Passage of the GENIUS Act: A Turning Point in Stablecoin and Digital Asset Regulation

Cozen O'Connor on

President Donald J. Trump has signed into law the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins of 2025 or the GENIUS Act of 2025), establishing the first comprehensive federal framework for...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

Robinson Bradshaw

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

Robinson Bradshaw on

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

K2 Integrity

The United States Terminates Countrywide Syria Sanctions and Is Working Towards Lifting Additional Trade Restrictions

K2 Integrity on

Building on prior relief of sanctions and other restrictive trade measures earlier this year (as described in K2 Integrity alerts dated 15 May and 09 June 2025), on 30 June 2025, U.S. President Donald Trump issued a new...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

Verrill

No Need to Report That Your Domestic Entity is Now Exempt from BOI Reporting Requirements

Verrill on

Through an Interim Final Rule that became effective March 26, 2025 (the “IFR”), the U.S. Treasury Department took action to exclude all U.S.-formed entities from the BOI[1] reporting regime under the Corporate Transparency...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

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

Ballard Spahr LLP on

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

Hogan Lovells on

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

Lowenstein Sandler LLP on

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

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