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FinCEN’s Proposed Foreign Affiliate SAR Sharing Program — Key Considerations

On January 25, 2022, the Financial Crimes Enforcement Network (“FinCEN”) solicited commentary regarding its proposed rule that would create a time-limited pilot program to expand the ability of financial institutions to share...more

FinCEN Rule Ends AML Program Exemption for Banks that Lack a Federal Regulator

On September 15, 2020, the Financial Crimes Enforcement Network (“FinCEN”) published a Final Rule bringing banks that lack a federal functional regulator further under its purview. The rule subjects these institutions to...more

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