News & Analysis as of

BSA/AML Financial Institutions

McGuireWoods LLP

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

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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

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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

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

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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

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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

Ballard Spahr LLP

Suspicious Activity Reports – What New Guidance Means for Financial Institutions

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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

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 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

Morrison & Foerster LLP

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

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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

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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

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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

Orrick, Herrington & Sutcliffe LLP

FinCEN Issues FAQs Clarifying SAR Reporting Requirements

On October 9, 2025, the Financial Crimes Enforcement Network (FinCEN), along with the banking and credit union regulators, issued guidance in the form of frequently asked questions (FAQs) addressing the regulatory...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

Haynes Boone

Financial Regulatory Roundup October 2025

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We’re pleased to share the October edition of our Financial Regulatory Roundup Newsletter, highlighting key developments shaping the financial regulatory landscape. In the latest issue we discuss: - NYDFS Issues Two...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions for September 2025

On September 18, the OCC announced its recent enforcement actions against national banks, federal savings associations, and individuals for September 2025. ...more

Troutman Pepper Locke

New York Issues Guidance on Blockchain Analytics for Banking Institutions

Troutman Pepper Locke on

On September 17, the New York State Department of Financial Services (DFS) issued new guidance on the use of blockchain analytics tools. This new guidance builds upon the blockchain guidance issued by DFS in 2022, and applies...more

Orrick, Herrington & Sutcliffe LLP

FDIC surveys its banks for anti-money laundering compliance costs

On September 12, the FDIC issued a notice and request for comment in the Federal Register for the general public and other federal agencies to provide feedback on the FDIC’s intent to survey the costs for FDIC insured...more

Jones Day

Senators Release Updated Discussion Draft of the "Responsible Financial Innovation Act of 2025"

Jones Day on

On September 5, 2025, Senators Tim Scott (R-SC), Cynthia Lummis (R-WY), Bill Hagerty (R-TN), and Bernie Moreno (R-OH) released an updated discussion draft of the "Responsible Financial Innovation Act of 2025" ("RFIA"), which...more

Orrick, Herrington & Sutcliffe LLP

FinCEN director signals AML reporting reform and highlights priorities in congressional testimony

On September 9, FinCEN Director Andrea Gacki testified before the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions, regarding FinCEN’s ongoing efforts to...more

Orrick, Herrington & Sutcliffe LLP

FinCEN issues guidance on cross-border information sharing for financial institutions

On September 5, FinCEN, in consultation with the FDIC, NCUA and the OCC, issued guidance to encourage the voluntarily cross-border sharing of information among financial institutions. ...more

Thomas Fox - Compliance Evangelist

All Things Investigations - FinCEN’s Recent Actions: Existential Threat for Financial Institutions in Mexico

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Jeremy Paner and Diego Durán de la Vega to discuss recent...more

Orrick, Herrington & Sutcliffe LLP

FinCEN releases notice to financial institutions on financial exploitation of minors

On September 8, FinCEN issued a notice to financial institutions to help identify and report suspicious activity related to financially motivated sextortion, an online threat with financial and social consequences for...more

Orrick, Herrington & Sutcliffe LLP

OCC terminates 2022 consent order against federally chartered digital asset bank

On August 18, the OCC terminated its 2022 consent order against a federally chartered bank specializing in digital assets. The OCC, in support of its decision, cited the safety and soundness of the bank and its compliance...more

Constangy, Brooks, Smith & Prophete, LLP

Wire Fraud: Should banks CYA by tightening up on KYC?

After a long weekend, Finance Manager Joe sits at his desk to read his emails. One of the emails is from a trusted vendor with whom the Joe communicates on a regular basis, regarding an unpaid invoice that is due immediately....more

Ballard Spahr LLP

32 Attorneys General call for enactment of marijuana banking legislation

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Thirty-two attorneys general representing states, territories and Washington, D.C. are asking Congress to pass legislation to provide financial institutions a safe harbor if they provide services to marijuana-related...more

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