The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more
3/14/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cartels ,
Executive Orders ,
Financial Services Industry ,
FinCEN ,
Geographic Targeting Order ,
Human Trafficking ,
Money Laundering ,
Reporting Requirements ,
Significant Transnational Criminal Organization ,
Trump Administration ,
U.S. Treasury
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more
9/6/2024
/ AML/CFT ,
Bank Secrecy Act ,
Biden Administration ,
Compliance ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Institutions ,
FinCEN ,
NPRM ,
Popular ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more
7/15/2024
/ AML/CFT ,
Anti-Money Laundering ,
Board of Directors ,
Compliance ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Oversight Committee ,
Proposed Rules ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Jan. 24, 2022, for implementing a pilot program allowing financial institutions to share suspicious activity...more
1/28/2022
/ Anti-Money Laundering ,
Comment Period ,
Financial Institutions ,
FinCEN ,
Foreign Jurisdictions ,
Foreign Subsidiaries ,
Internal Controls ,
Proposed Regulation ,
Reporting Requirements ,
Subsidiaries ,
Suspicious Activity Reports (SARs)
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Dec. 7, 2021, seeking to implement the "beneficial ownership information" (BOI) requirement of the Corporate...more
12/15/2021
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Commodity Exchange Act (CEA) ,
Corporate Transparency Act ,
Disclosure Requirements ,
FinCEN ,
NPRM ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more
7/7/2021
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Banking Sector ,
Biden Administration ,
Cyber Crimes ,
Drug Trafficking ,
Enforcement Priorities ,
Financial Institutions ,
FinCEN ,
Fraud ,
Human Trafficking ,
Mexico ,
Money Laundering ,
New Guidance ,
Nonbank Firms ,
Office of Foreign Assets Control (OFAC) ,
Policy Statement ,
Popular ,
Russia ,
Significant Transnational Criminal Organization ,
Smuggling ,
State Sponsors of Terrorism ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations ,
U.S. Treasury ,
Virtual Currency
The Anti-Money Laundering Act of 2020 (AMLA 2020) became law on Jan. 2, 2020, when Congress overrode President Donald Trump's veto of the National Defense Authorization Act. AMLA 2020 is the most consequential anti-money...more
1/14/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Congressional Override ,
Criminal Penalties ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Foreign Banks ,
Mutual Legal Assistance Treaties (MLAT) ,
NDAA ,
Presidential Veto ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
• The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) continues to expand its Geographic Targeting Orders (GTOs) with respect to beneficial ownership transparency in real estate...more
The Financial Crimes Enforcement Network (FinCEN) on Aug. 25, 2016, issued a notice of proposed rulemaking (Proposed Rule) to implement Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools...more
8/29/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Non-Resident Aliens ,
Puerto Rico ,
Regulatory Standards ,
Virgin Islands
In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more
5/20/2016
/ Bank Accounts ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
FATCA ,
Financial Institutions ,
FinCEN ,
Foreign-Owned Corporations ,
Geographic Targeting Order ,
IRS ,
Money Laundering ,
Mossack Fonseca ,
Office of Foreign Assets Control (OFAC) ,
Offshore Funds ,
Panama Papers ,
Shell Corporations ,
Tax Evasion ,
Tax Haven ,
Wire Transfers
On April 21, 2015 – after months of speculation by those in the Bank Secrecy Act/anti-money laundering compliance community – the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in...more
August was a busy month for the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). Among other initiatives, FinCEN issued its long-awaited proposed regulations on customer due diligence (CDD)...more
9/4/2014
/ Advisory Opinions ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Compliance ,
Cross-Border Transactions ,
Due Diligence ,
Enforcement Actions ,
FATF ,
Financial Institutions ,
FinCEN ,
Mexico ,
Proposed Regulation ,
Rulemaking Process
On Aug. 11, 2014, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued FIN-2014-A007 (the "Advisory"). Among other things, the Advisory highlights the importance of maintaining a strong...more