News & Analysis as of

U.S. Treasury Risk Assessment

Bressler, Amery & Ross, P.C.

NY Department of Financial Services Issues Guidance to its Regulated Industry As a Result of the Ongoing Global Conflict

The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more

Health Care Compliance Association (HCCA)

Managing Sanctions Compliance

It’s not a good time to be a manufacturer of ten-foot poles. That’s because with the growing number of sanctions regimes, there are an increasing number of companies and individuals that businesses shouldn’t touch with a poll...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

Paul Hastings LLP

Implications for Mexican Banks and Financial Institutions of President Trump’s Designation of Drug Cartels as Foreign Terrorist...

Paul Hastings LLP on

On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more

Morrison & Foerster LLP

FinCEN Expands its Reach with Final Rules for Investment Advisers and the Residential Real Estate Sector

Key Takeaways - •FinCEN has issued two new final rules to significantly expand regulation around certain investment adviser and residential real estate sectors to combat illicit finance in these areas. These highly...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

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - June 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Harris Beach Murtha PLLC

Rule Would Subject More Real Estate Transactions to Review

On July 8, 2024, the U.S. Department of the Treasury issued a Notice of Proposed Rulemaking that would expand the geographical areas in which real estate transactions would be subject to Committee on Foreign Investment in the...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

WilmerHale

Treasury Issues Request for Information on Uses of AI

WilmerHale on

On June 6, 2024, the US Department of the Treasury (Treasury) issued a request for information (RFI) on the “uses, opportunities and risks of artificial intelligence (AI) in the financial services sector.” The RFI seeks...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

On June 6, the U.S. Department of the Treasury (Treasury) issued a request for information (RFI) seeking public input on the uses, opportunities, and risks presented by the use of artificial intelligence (AI) within the...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

Mintz - Antitrust Viewpoints

Treasury Department Warns Financial Institutions to Prepare for AI-Age Fraud — AI: The Washington Report

Pursuant to President Biden’s October 2023 AI executive order, the US Department of Treasury (Treasury) released a report on cybersecurity risks in the financial services sector in March 2024. While recognizing the...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...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

Morrison & Foerster LLP

FinCEN: Eyes on Investment Advisers

In July 2020, a sensitive Federal Bureau of Investigation (FBI) document was leaked to the public. The document outlined the FBI’s suspicions that the private investment funds industry was providing choice money laundering...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 2

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 focusing on:...more

McDermott Will & Emery

CFTC Crackdown: Three DeFi Platforms Face Enforcement Actions

McDermott Will & Emery on

On September 7, 2023, the Commodity Futures Trading Commission (CFTC) simultaneously filed and settled charges against three decentralized finance (DeFi) platforms, signaling a significant step toward CFTC regulatory...more

Shipkevich PLLC

US Treasury Releases Risk Assessment Report on Decentralized Finance

Shipkevich PLLC on

On April 6, 2023, the US Department of the Treasury released a report analyzing the risks of decentralized finance (DeFi) and potential vulnerabilities in the United States' anti-money laundering (AML) and countering the...more

BakerHostetler

CBDC Pilot Announced; Ethereum Upgrade Completed; U.S. Treasury Department Addresses DeFi Risks; Studies Analyze Crypto Taxation,...

BakerHostetler on

Montenegro Announces CBDC Pilot, BIS Compares CBDCs to Stablecoins - According to a recent press release, “The Central Bank of Montenegro (CBCG) has agreed to collaborate with the enterprise crypto and blockchain solutions...more

Paul Hastings LLP

Treasury’s DeFi Risk Assessment Draws Lines in the Sand Around “Control”

Paul Hastings LLP on

On April 6, 2023, Treasury issued its risk assessment for decentralized financial (“DeFi”) services as required by Executive Order 14067. While not guidance, the Risk Assessment can provide some insight into Treasury’s views...more

K2 Integrity

U.S. Authorities Amplify Enforcement Efforts to Address Financial Crime Risks in the Digital Asset Industry

K2 Integrity on

The United States Department of the Treasury has continued to signal that it will focus policy, regulatory, and enforcement attention on the financial crime and sanctions risk in the crypto and digital asset ecosystem...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2022

Headlines: ..OCC Publishes Security Standards for Video Teleconferencing With Agency Staff ..CFPB Imposes Civil Penalty and Customer Refunds for Authorized-Positive Overdraft Fees ..Treasury Department Recommends...more

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