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)
On October 29, 2025, Paul Atkins, Chairman of the Securities and Exchange Commission (“SEC”), signaled that he will ask SEC staff to evaluate relief for certain firms who engage in a de minimis level of security-based swap...more
On October 21, 2025, Governor Christopher J. Waller of the Board of Governors of the Federal Reserve System (the “Federal Reserve”) delivered opening remarks at the inaugural Payments Innovation Conference (the...more
On October 17, 2025, the National Futures Association (“NFA”) announced a proposal to repeal requirements that firms that are registered with the Commodity Futures Trading Commission (“CFTC”) must make certain disclosures to...more
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
On September 30, 2025, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission granted no-action relief that allows, subject to numerous conditions: (i) investment advisers registered...more
10/13/2025
/ Banks ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Investment Advisers Act of 1940 ,
Investment Company Act of 1940 ,
Investment Funds ,
No-Action Letters ,
Registered Investment Advisors ,
Registered Investment Companies (RICs) ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
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
On August 18, 2025, Illinois enacted Senate Bill 1797, the Digital Assets and Consumer Protection Act (the “Act”), establishing a regulatory framework designed to enhance customer protections for digital asset activities and...more
9/4/2025
/ Blockchain ,
Consumer Protection Laws ,
Cryptocurrency ,
Digital Assets ,
Disclosure Requirements ,
Financial Services Industry ,
Illinois ,
New Legislation ,
Regulatory Oversight ,
Regulatory Requirements ,
State and Local Government
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 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more
4/9/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Investment Products ,
OCC ,
Regulatory Reform ,
Regulatory Requirements ,
Stablecoins
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 March 13, 2025, the US Senate Banking Committee passed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 or “GENIUS Act,” out of committee by a vote of 18-6....more
3/20/2025
/ Bankruptcy Code ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
OCC ,
Regulatory Requirements ,
Stablecoins ,
U.S. Treasury
On March 7, 2025, the Office of the Comptroller of the Currency (OCC) issued guidance on national bank and federal savings association participation in certain cryptocurrency activities (“IL 1183”). This guidance is 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
The US Consumer Financial Protection Bureau (CFPB) is giving no-action letters (NALs) a second chance. On January 8, 2025, the CFPB issued a policy statement setting forth new procedures for companies to request supervisory...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
Join us for a new episode of Financial Services Focus with partners Gina Parlovecchio and Matthew Bisanz, and associate Kelly Truesdale, as they discuss FinCEN’s recent confirmation that reporting companies are not required...more
12/17/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Requirements ,
Financial Services Industry ,
FinCEN ,
Popular ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
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 October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rulemaking on Personal Financial Data Rights (the “Final Rule”). The Final Rule is intended to accelerate a shift towards open banking in the...more
11/6/2024
/ Banks ,
Consumer Data Requests ,
Consumer Financial Protection Bureau (CFPB) ,
Data Management ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking ,
Popular