On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) that would formalize and, in certain respects, update the requirements...more
4/10/2026
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Notice of Proposed Rulemaking (NOPR) ,
NPRM ,
Proposed Rules ,
Regulatory Oversight ,
Regulatory Reform ,
Risk Assessment ,
Risk Management ,
Risk-Based Approaches
On March 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) submitted a Notice of Proposed Rulemaking (“NPRM”) for publication in the Federal Register that would, for the first...more
4/1/2026
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
National Security ,
NPRM ,
Office of Foreign Assets Control (OFAC) ,
Proposed Rules ,
Reporting Requirements ,
Sanctions ,
U.S. Treasury ,
Whistleblower Awards ,
Whistleblowers
On March 6, 2026, the SEC and FinCEN announced parallel enforcement actions against a New York-based registered broker-dealer for systemic anti-money laundering (“AML”) failures, imposing combined penalties of $80 million –...more
3/13/2026
/ AML/CFT ,
Anti-Money Laundering ,
Broker-Dealer ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Enforcement Actions ,
FinCEN ,
Internal Controls ,
Money Laundering ,
Penalties ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
On July 11, 2025, in United States v. Schena, the U.S. Court of Appeals for the Ninth Circuit issued the first appellate decision interpreting the Eliminating Kickbacks in Recovery Act (“EKRA”). The decision marks a...more
On June 9, Deputy Attorney General Todd Blanche issued a memorandum to the Department of Justice’s Criminal Division, outlining the Department’s focus for pending and future FCPA actions. ...more
On June 16, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (USAO-SDTX) announced their decision to decline prosecution of White Deer...more
6/18/2025
/ Acquisition Agreements ,
Bureau of Industry and Security (BIS) ,
Criminal Prosecution ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Merger Agreements ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Safe Harbors
Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices...more
2/14/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA)....more
In recent years, the Biden Administration has been vocal that combatting foreign public corruption is a key pillar of its national security efforts.orr Consistent with those policy goals, on December 22, 2023, Congress...more
In the U.S. Department of Justice’s continuing efforts to incentivize voluntary disclosure of corporate misconduct, Deputy Attorney General Lisa Monaco announced the Criminal Division’s latest corporate self-disclosure policy...more