News & Analysis as of

Bank Secrecy Act

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
Bradley Arant Boult Cummings LLP

FinCEN’S New Real Estate Reporting Rule: Historical Context, Compliance Requirements, Legal Challenges and What ACMA Members Need...

Bradley Arant Boult Cummings LLP on

In August 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a sweeping new rule aimed at increasing transparency in residential real estate transactions—marking a significant...more

Mayer Brown

FinCEN Publishes FAQs to Reduce Certain Compliance Burdens Associated with SAR Filings

Mayer Brown on

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

Frost Brown Todd

Bill Introduced to Increase Reporting Thresholds Under the Bank Secrecy Act

Frost Brown Todd on

On October 21, 2025, the Senate Committee on Banking, Housing, and Urban Affairs introduced S.B. 3017, titled the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act...more

Bradley Arant Boult Cummings LLP

Less Noise, More Signal: What FinCEN’s New SAR Guidance and the STREAMLINE Act Could Mean for BSA Reporting

Bradley Arant Boult Cummings LLP on

Two recent developments signal that momentum is building in Washington to recalibrate Bank Secrecy Act (BSA) reporting to produce higher‑value intelligence with less compliance friction. First, on October 9, 2025, the...more

Parker Poe Adams & Bernstein LLP

Senate Republicans Introduce Bill Proposing to Raise Anti-Money Laundering Thresholds

Parker Poe Adams & Bernstein LLP on

On October 21, 2025, Senate Republicans introduced a new bill that would increase the threshold amounts applicable to certain currency transaction reports and suspicious activity reports under the Bank Secrecy Act (BSA). The...more

Friling Law

Selling Property in Iran and Transferring Proceeds to the United States: Comprehensive Legal, Sanctions, and Compliance Guide

Friling Law on

I. Executive Overview - In recent years, many Iranian-Americans have faced growing uncertainty when trying to manage property or financial ties in Iran. One of the most sensitive issues is what happens when someone sells...more

BakerHostetler

Weekly Blockchain Blog - November 2025

BakerHostetler on

US Payments and Digital Asset Companies Announce Stablecoin Initiatives - On Oct. 28, a U.S.-based multinational money transfer company announced the launch of its stablecoin, the U.S. Dollar Payment Token (USDPT)....more

Orrick, Herrington & Sutcliffe LLP

FinCEN issues new Financial Trend Analysis identifying $9B in Iranian shadow banking activity in 2024

Orrick, Herrington & Sutcliffe LLP on

On October 23, FinCEN released a new Financial Trend Analysis identifying approximately $9 billion in potential Iranian shadow banking activity that flowed through U.S. correspondent accounts in 2024. The analysis, based on...more

Ballard Spahr LLP

FinCEN Releases Data Showing $9 Billion in Iranian Shadow Banking Activity

Ballard Spahr LLP on

On October 23, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Financial Trend Analysis (“FTA”), identifying $9 billion of potential Iranian shadow banking activity in...more

McGuireWoods LLP

Reducing BSA Compliance Obligations? A Look at the Senate’s STREAMLINE Act

McGuireWoods LLP on

The Senate has introduced the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act, or the STREAMLINE Act, an initiative led by Senate Banking Committee Chairman Tim Scott and...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – October 2025 # 4

Troutman Pepper Locke on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Allen Barron, Inc.

FBAR Requirements as a U.S. Person for an Offshore Account

Allen Barron, Inc. on

What are your FBAR requirements as a U.S. person or taxpayer for an offshore account, group of accounts, property, or investment? The penalties for non-compliance with reporting offshore accounts, assets, and income are...more

Sheppard Mullin Richter & Hampton LLP

OCC Settles with Bank Over Alleged BSA/AML Violations

Sheppard Mullin Richter & Hampton LLP on

On October 16, the OCC announced a formal agreement with a national bank in Florida for alleged unsafe or unsound practices related to board oversight, corporate governance, strategic and capital planning, and compliance with...more

McGuireWoods LLP

FinCEN Eyes Easing Compliance Burdens on Financial Institutions

McGuireWoods LLP on

The Financial Crimes Enforcement Network (“FinCEN”) has recently taken two steps in furtherance of the Trump Administration’s deregulatory agenda.  ...more

Benesch

The “Streamline Act” Seeks to Raise Reporting Thresholds and Modernize the Bank Secrecy Act

Benesch on

On October 21, 2025, U.S. Senators unveiled a bill that would increase reporting thresholds for currency transaction reports (“CTRs”) and suspicious activity reports (“SARs”) under the Bank Secrecy Act (“BSA”)....more

Friling Law

OFAC Whistleblowing: Exposing Sanctions Violations Under U.S. Law

Friling Law on

The Office of Foreign Assets Control (OFAC) stands among the most influential arms of the U.S. Department of the Treasury, charged with administering and enforcing economic and trade sanctions that safeguard national...more

Ballard Spahr LLP

Suspicious Activity Reports – What New Guidance Means for Financial Institutions

Ballard Spahr LLP on

On October 9, 2025, the Financial Crimes Enforcement Network (“FinCEN”) jointly issued updated Frequently Asked Questions (“FAQs”) with the Federal Reserve Board of Governors, the Federal Deposit Insurance Corporation, the...more

Brownstein Hyatt Farber Schreck

FinCEN Seeks to Clarify Suspicious Activity Reporting Obligations Under the BSA

Brownstein Hyatt Farber Schreck on

The Federal Crimes Enforcement Network (FinCEN) recently issued some rare, detailed guidance concerning the filing of Suspicious Activity Reports (SARs), impacting how financial institutions and larger casinos comply with...more

Orrick, Herrington & Sutcliffe LLP

FinCEN seeks comment on proposed survey of compliance costs for fintechs

Orrick, Herrington & Sutcliffe LLP on

Recently, FinCEN published a notice in the Federal Register requesting public comment on a proposed new information collection titled the “Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism...more

Orrick, Herrington & Sutcliffe LLP

FinCEN renews geographic targeting orders for title insurance companies through Feb. 2026

Orrick, Herrington & Sutcliffe LLP on

On October 9, FinCEN announced it had renewed geographic targeting orders (GTOs) requiring title insurance companies in designated locales to report information on cash residential real estate transactions....more

Sheppard Mullin Richter & Hampton LLP

DFPI Orders Crypto Kiosk Operator to Cease Operations for Alleged Violations of Digital Financial Assets Law

Sheppard Mullin Richter & Hampton LLP on

On October 6, the DFPI issued a Desist and Refrain Order against a digital-asset ATM operator for alleged violations of the California Digital Financial Assets Law (DFAL) and the California Consumer Financial Protection Law...more

Ballard Spahr LLP

FinCEN Renews Geographic Targeting Order

Ballard Spahr LLP on

On October 9, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a renewal of its Geographic Targeting Order (“GTOs”), which require U.S. title insurance companies, including their subsidiaries and agents, to...more

Morrison & Foerster LLP

FinCEN Streamlines SAR Guidance: New FAQs Focus on Risk-Based AML Compliance

Morrison & Foerster LLP on

On October 9, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly with the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance...more

K2 Integrity

The Fourth Pillar Of An AML Program: Establishing An Independent Audit That Stands Up To Scrutiny

K2 Integrity on

An AML program is only as strong as its weakest pillar. Internal controls can look airtight. Compliance officers can be seasoned. Training can be thorough. But if the independent audit is weak, everything else risks collapse....more

King & Spalding

FinCEN Relaxes Suspicious Activity Reporting Requirements Via Four New FAQs

King & Spalding on

On October 9, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National...more

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