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FinCEN Issues Proposed Whistleblower Rule to Incentivize AML Reporting and Compliance

The Financial Crimes Enforcement Network (FinCEN) on April 1, 2026, published a Notice of Proposed Rulemaking (Proposed Rule) regarding regulations implementing the whistleblower provisions of the Bank Secrecy Act (BSA). The...more

FinCEN Imposes Record Penalty on Broker-Dealer: Compliance Lessons Going Forward

The Financial Crimes Enforcement Network (FinCEN) entered into a consent order on March 6, 2026, imposing an $80 million civil money penalty against a global broker-dealer (Broker-Dealer)  – the largest Bank Secrecy Act (BSA)...more

Recent FinCEN Actions Signal Trump Administration's Focus on Escalating AML Enforcement

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) recently announced a sweeping enforcement operation targeting money services businesses (MSBs) operating along the Southwest U.S. border....more

OFAC Authorizes Certain Venezuelan Oil Sector Activities Following Venezuelan Reform​

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued two general licenses to provide limited sanctions relief for Venezuela's oil sector after the Venezuelan National Assembly passed...more

U.S. Sanctions Colombia's President Under Global Illicit Drug Trade Program

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 24, 2025, designated the Republic of Colombia's sitting president, Gustavo Francisco Petro Urrego (Petro), pursuant to Executive Order (EO)...more

FinCEN Geographic Targeting Order Imposes Additional Recordkeeping and Reporting Requirements

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

OFAC Terminates License Authorizing Certain Petroleum-Related Activities in Venezuela

President Donald Trump announced on Feb. 26, 2025, that he was reversing the authorization granted to Chevron Corp. and its subsidiaries (Chevron) by the Biden Administration as a concession aimed at promoting free elections...more

Trump Administration Announces Designation of International Cartels

U.S. President Donald Trump issued Executive Order 14157 (the EO) on Jan. 20, 2025, calling for the designation of drug cartels and other foreign organizations as foreign terrorist organizations (FTOs) or specially designated...more

Trump Threatens Retaliatory Measures vs. Latin American Countries Refusing Repatriation Flights

President Donald Trump on Jan. 20, 2025, issued various immigration-related Executive Orders (EOs) and presidential actions that could have an immediate and lasting impact on Latin American countries. President Trump's...more

Trump Administration Rescinds Certain Actions by the Previous Administration to Ease Cuba Sanctions

Within hours after taking office on Jan. 20, 2025, U.S. President Donald Trump signed an omnibus executive order revoking 78 executive actions by the previous administration, dating back to 2021. Among them, President Trump...more

U.S. Announces Steps to Ease Cuba Sanctions

Besides certain expansions on remittances in 2022, the White House, on Jan. 14, 2025, issued a statement announcing President Joe Biden's plans to relax sanctions on Cuba through a series of broad measures aimed at improving...more

Corporate Transparency Act Reporting

The Corporate Transparency Act (CTA) requires "Reporting Companies" – domestic entities created by the filing of a document with a secretary of state and non-U.S. entities that have registered to do business in the United...more

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

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

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

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

FinCEN Issues Proposed Rule Amending Requirements of Financial Institutions' AML/CFT Programs

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

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

OFAC Amends Regulations to Support Cuban People, Independent Private-Sector Entrepreneurs

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, support independent Cuban private-sector...more

CTA Heats Up with New FAQs, Government and Amicus Briefs and New Draft Legislation

The Corporate Transparency Act (CTA) is the gift that keeps giving. As affected entities and their advisers struggle to determine whether they are subject to the beneficial ownership information (BOI) reporting provisions of...more

OFAC Revokes General License 44 Related to Venezuela's Oil and Gas Sector

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 44A (GL 44A) on April 17, 2024, replacing and superseding General License 44 (GL 44). On Oct. 18, 2023, OFAC suspended...more

OFAC Suspends Certain U.S. Sanctions with Respect to Venezuela

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 18, 2023, suspended certain U.S. sanctions under the Venezuela Sanctions Regulations (VSR), including measures on Venezuela's oil and gas...more

FinCEN Issues Final Rule Implementing Corporate Transparency Act Requirement

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule on Sept. 29, 2022, implementing the beneficial ownership information (BOI) reporting requirement of the Corporate...more

Federal Bank Regulators Issue Joint Guidance on Hemp

Today the federal bank regulatory agencies issued joint guidance on Providing Financial Services to Customers Engaged in Hemp-Related Businesses (Joint Hemp Guidance). These agencies – the Office of the Comptroller of the...more

U.S. Imposes Comprehensive Sanctions Blocking Property of the Government of Venezuela

• President Donald Trump has issued an Executive Order expanding the current sanctions relating to Venezuela by blocking all property and interests in property of the government of Venezuela and the Nicolás Maduro...more

Ambassador Bolton Warns of Potential U.S. Secondary Sanctions Against Venezuela - Non-U.S. Entities Transacting with Certain...

• National Security Advisor Ambassador John Bolton issued a statement threatening sanctions against non-U.S. banks for facilitating illegitimate transactions with certain Venezuelan individuals and entities. • This...more

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