On November 24, 2025, the US Office of Foreign Assets Control (“OFAC”) announced a $4,677,552 penalty against an individual (acting through a US real estate investment company) for willfully purchasing and renovating real...more
On October 9, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the...more
11/12/2025
/ AML/CFT ,
Bank Secrecy Act ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
In July, Congress passed, and President Donald Trump signed, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”). The GENIUS Act was a watershed moment in the history of...more
10/23/2025
/ Anti-Money Laundering ,
Banks ,
Cryptocurrency ,
Digital Assets ,
Financial Services Industry ,
FinTech ,
New Legislation ,
Proposed Rules ,
Regulatory Requirements ,
Rulemaking Process ,
Stablecoins ,
The GENIUS Act ,
U.S. Treasury
The podcast dives into the fast-evolving world of stablecoins, explaining how these dollar-pegged digital assets are transforming payments with speed, transparency, and fractional flexibility. We also delve into the GENIUS...more
On September 30, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a request for information (“AML Survey”) on the costs that nonbank financial institutions (“NBFIs”) incur to comply with anti-money laundering...more
EXECUTIVE SUMMARY -
On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its first orders (“Orders”) pursuant to the 2024 FEND Off Fentanyl Act (21 U.S.C. § 2313a)...more
On June 18, 2025, the Financial Action Task Force (“FATF”) revised the Travel Rule requirements for certain funds transfers (the “2025 Revisions”). The 2025 Revisions are intended to adapt anti-money laundering (“AML”)...more
Earlier yesterday, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the...more
In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more
7/21/2025
/ Anti-Money Laundering ,
Cartels ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Foreign Policy ,
International Trade ,
Mexico ,
National Security ,
Sanctions ,
Terrorism Funding ,
Terrorist Financing Regulations
On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more
On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued Interpretative Letter 1184 (“IL 1184”) confirming that national banks and federal savings associations may provide cryptocurrency custody...more
5/20/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Regulatory Reform ,
FinTech ,
New Guidance ,
OCC ,
Regulatory Authority ,
Regulatory Requirements ,
Trump Administration
On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more
Millions of reporting companies breathed a sigh of relief on March 21, 2025, when the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempted all domestic entities from...more
On March 21, 2025, the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempts all domestic entities from beneficial ownership information reporting requirements under the...more
On February 27, 2025, the US Financial Crimes Enforcement Network (FinCEN) announced that it will not issue fines or penalties or take any other enforcement actions against companies that fail to comply with the March 21,...more
AT A GLANCE -
On February 17, 2025, the US District Court for the Eastern District of Texas stayed its January 7 order, enjoining enforcement of the Corporate Transparency Act and suspending the effectiveness of the...more
2/28/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements
AT A GLANCE -
The US Supreme Court has stayed the injunction against the Corporate Transparency Act (CTA), but the requirement for companies to file beneficial ownership information remains suspended, creating ongoing...more
On December 26, 2024, a panel of the US Court of Appeals for the Fifth Circuit vacated an order issued by a different panel just days before that had stayed the nationwide preliminary injunction suspending enforcement of the...more
12/31/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 23, 2024, the US Court of Appeals for the Fifth Circuit granted an emergency motion by the federal government to stay the nationwide preliminary injunction that had suspended enforcement of the Corporate...more
12/27/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 7, 2024, the US Financial Crimes Enforcement Network (FinCEN) confirmed that reporting companies—i.e., companies that would be required to report their beneficial ownership information to FinCEN under the...more
12/11/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 3, 2024, the US District Court for the Eastern District of Texas entered a preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementing regulations nationwide,...more
12/10/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a rule to require reporting of certain US residential real estate transactions (“Final Rule”). The Final Rule...more
On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more
On July 8, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued interpretive guidance explaining that the beneficial ownership information (“BOI”) reporting requirement applies to certain legal entities that have...more
I. INTRODUCTION -
On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more
5/31/2024
/ Anti-Money Laundering ,
Compliance ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
NPRM ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC)