News & Analysis as of

BSA/AML Regulatory Requirements

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

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

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

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

Phelps Dunbar

Agentic AI: Opportunities and Compliance Considerations for Community Banks

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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

Loeb & Loeb LLP

GENIUS Act: Payment Stablecoins Coming to a Retailer Near You (Maybe)

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The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) (S. 1582) establishes the first U.S. framework specifically regulating “payment stablecoins,” and sets forth regulatory and licensing...more

Patomak Global Partners

Understanding the New De-Banking Executive Order

Situation Overview: On August 7, 2025, President Trump issued an Executive Order (the “Order”) entitled “Guaranteeing Fair Banking for All Americans”, which has implications for retail and institutional fair lending...more

Adams & Reese

FinCEN Postpones Residential Real Estate Reporting Requirement Until March 2026

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FinCEN announced today that the reporting requirements for the “Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule” (RRE Rule) have been postponed until March 1, 2026. The previous deadline was Dec....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

Orrick, Herrington & Sutcliffe LLP

OCC announces actions to address politicized debanking practices

On September 8, the OCC announced new actions that aim to eliminate “politicized or unlawful debanking” in the federal banking system, consistent with Executive Order 14331: “Guaranteeing Fair Banking For All Americans”...more

Carlton Fields

FinCEN Postpones Opening Night for RIA AML Programs

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On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone, for two years, the effective date of a final rule subjecting investment advisers to the anti-money laundering (AML)...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

Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm on Conspiracy to Operate an Unlicensed...

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On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was...more

Conyers

BVI Corporate Review – Q2 2025

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As outlined in our Q1 2025 review, important amendments to BVI company law came into effect as of 2 January 2025, including a requirement to file beneficial ownership information through the VIRRGIN system maintained by the...more

Orrick, Herrington & Sutcliffe LLP

FDIC Approves Use of Pre-Populated Customer Information During Account Opening

On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more

Ballard Spahr LLP

FDIC clarifies that CIP Rule does not preclude using pre-populated customer information

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On August 5, 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL-39-2025 to state that an FDIC-supervised institution can use pre-populated customer information to satisfy the requirements of the Customer...more

Bradley Arant Boult Cummings LLP

How Banks Can Harness New Customer ID Rule's Flexibility

Financial institutions across the U.S. have grappled with compliance requirements under the Customer Identification Program, or CIP, rule for more than two decades. On June 27, the Federal Deposit Insurance Corp., the...more

Haynes Boone

FinCEN Announces Intention to Postpone Effective Date of Anti-Money Laundering Rule for Registered Investment Advisers and Exempt...

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FinCEN will work through the rulemaking process to formally extend the IA AML Rule effective date and intends to provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective...more

Eversheds Sutherland (US) LLP

The GENIUS Act: US law for payment stablecoins

The first piece of major US federal legislation in the global digital assets space was signed into law on July 18, 2025, by President Trump.1 Declared by President Trump as positioning the United States to be the “crypto...more

Alston & Bird

Financial Institutions Permitted to Use Third Parties to Collect Customers’ Taxpayer Identification Numbers for Identity...

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Our Financial Services and White Collar, Government & Internal Investigations Teams examine the Financial Crimes Enforcement Network’s new customer identification program (CIP) exemption that allows banks and credit unions to...more

Foley & Lardner LLP

Thorny Laws That ICHRA Vendors Should Consider, Part Three: FinTech Edition

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We continue our series on the legal and regulatory challenges facing individual coverage health reimbursement arrangements (ICHRAs); this time, we are focusing on the fintech-related requirements that may apply to ICHRA...more

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

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