On December 22, FinCEN announced a multi-tiered operation targeting more than 100 money services businesses (MSBs) operating along the southwest border for potential noncompliance with BSA/AML regulations. ...more
On December 22, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a multifaceted data-driven operation to address potential money laundering, focused on more than 100 U.S....more
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
Even amid the historic government shutdown, crypto policy continues to evolve, with courts, Congress and regulators moving forward on major issues. The U.S. Court of Appeals for the 10th Circuit affirmed that Federal Reserve...more
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
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
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
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
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
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
Following up and consistent with public statements earlier this summer, FinCEN has formally proposed a two year delay of the effective date of its 2024 final rule that subjects certain investment advisers to the requirements...more
On September 8, the Treasury through FinCEN issued additional reporting requirements on financial institutions through its Geographic Targeting Order (GTO). This GTO will require certain money services businesses along the...more
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
In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more
On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more
We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more
On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more
On March 11, FinCEN issued a Geographic Targeting Order (GTO) to combat “illicit activities and money laundering of Mexico-based cartels” along the U.S. southwest border. The order requires money service businesses in select...more
On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more
On 15 January 2025, K2 Integrity hosted a webinar that featured Justina Rousseau, senior managing director at K2 Integrity; Aseel Rabie, counsel at Debevoise & Plimpton LLP; and Sarah Runge, executive managing director at K2...more
On 10/10/24, FinCEN assessed a record $1.3 billion penalty against TD Bank for BSA violations. This unprecedented penalty should function as a cautionary message and a warning to all financial institutions. All financial...more
The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”). The Consent Order describes Lake...more
On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more
On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more