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BSA/AML Anti-Money Laundering

Frost Brown Todd

Bill Introduced to Increase Reporting Thresholds Under the Bank Secrecy Act

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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

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

Orrick, Herrington & Sutcliffe LLP

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

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

WilmerHale

FinCEN Clarifies Suspicious Activity Reporting Requirements

WilmerHale on

On October 9, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the prudential regulators issued joint guidance clarifying regulatory expectations for suspicious activity reports...more

Sheppard Mullin Richter & Hampton LLP

OCC Settles with Bank Over Alleged BSA/AML Violations

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

Orrick, Herrington & Sutcliffe LLP

OCC announces enforcement actions for October 2025, including one formal agreement

On October 16, the OCC announced enforcement actions for October, including one new formal agreement and four terminations of prior agreements. The OCC entered into a formal agreement with a national bank in September after...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

Loeb & Loeb LLP

OCC Grants Conditional Approval to First Full-Service Crypto Bank

Loeb & Loeb LLP on

Marking a significant milestone in the acceptance of cryptocurrency into the world of traditional finance, the Office of the Comptroller of the Currency (OCC) has granted conditional approval for a national bank charter to...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

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

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – October 2025 # 3

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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

Brownstein Hyatt Farber Schreck

FinCEN Seeks to Clarify Suspicious Activity Reporting Obligations Under the BSA

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

Proskauer - Whistleblower Defense

Court Narrowly Interprets Whistleblower Protections Under AMLA and FIRREA

On September 23, 2025, in Park v. Shinhan Bank America, the U.S. District Court for the Southern District of New York dismissed whistleblower retaliation claims brought by four former compliance officers of Shinhan Bank...more

Orrick, Herrington & Sutcliffe LLP

FinCEN seeks comment on proposed survey of compliance costs for fintechs

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

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

Clark Hill PLC

Anti-Money Laundering Rules: Ethical Requirements for Attorneys as Reporting Persons

Clark Hill PLC on

This article explains the requirements of a new anti-money laundering rule that, when effective on March 1, 2026, will require suspicious activity reporting from advisors (including attorneys) who assist clients with certain...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

Davis Wright Tremaine LLP

Wolfsberg Report Casts Light on Path Forward for Crypto Risk Management

New analysis provides insights into managing AML risks for digital asset entities - Detailed recommendation for modern risk management design...more

Troutman Pepper Locke

Navigating the Latest SAR FAQs

Troutman Pepper Locke on

On October 8, the Office of the Comptroller of the Currency (OCC), in collaboration with the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance...more

Phelps Dunbar

Agentic AI: Opportunities and Compliance Considerations for Community Banks

Phelps Dunbar on

Artificial intelligence has quickly moved from abstract discussion to operational reality. The newest development—“agentic” AI—goes beyond chat interfaces and predictive analytics. These systems are designed to initiate,...more

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