News & Analysis as of

Financial Crimes

Ballard Spahr LLP

FinCEN Proposes Rule to Increase Whistleblower Incentives

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FinCEN has published a Notice of Proposed Rulemaking (“NPRM”) that would formalize and expand its whistleblower program, offering potentially substantial financial payouts to whistleblowers reporting certain financial crimes....more

Holland & Knight LLP

FinCEN Issues Proposed Whistleblower Rule to Incentivize AML Reporting and Compliance

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The Financial Crimes Enforcement Network (FinCEN) on April 1, 2026, published a Notice of Proposed Rulemaking (Proposed Rule) regarding regulations implementing the whistleblower provisions of the Bank Secrecy Act (BSA). The...more

Orrick, Herrington & Sutcliffe LLP

What Companies Need to Know About FinCEN’s Proposed Whistleblower Program

A proposed rule implementing the whistleblower program from U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) could significantly increase enforcement risk for companies subject to anti-money...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Proposed Rule on AML/CFT Program Requirements: Key Implications

On April 7, 2026, the Financial Crimes Enforcement Network (FinCEN) issued a proposed rule that would revise anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements under the Bank...more

Littler

Blow the Whistle, Get Paid: Treasury’s New Proposed Weapon Against Financial Crimes, Including Healthcare Fraud

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On March 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a proposed rule to implement a new whistleblower reward program. The proposed whistleblower program would follow...more

Alston & Bird

Cybercrime Trends to Watch: Takeaways from the FBI’s 2025 IC3 Annual Report

Alston & Bird on

On April 6, 2026, the Federal Bureau of Investigation (FBI) released its 2025 IC3 Annual Report, which provides key trends, case data, and other statistics related to the FBI’s ongoing efforts to combat emerging cybersecurity...more

Ballard Spahr LLP

FinCEN’s Proposed Rule to Reform Financial Institution AML/CFT

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As part of the U.S. Department of Treasury’s efforts to modernize the U.S. anti-money laundering regulatory and supervisory framework, the Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would...more

Ropes & Gray LLP

DOJ Establishes National Fraud Enforcement Division

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On April 7, 2026, Acting Attorney General Todd Blanche issued a memorandum (the “Memorandum”) formally establishing the National Fraud Enforcement Division (“Fraud Division”) within the Department of Justice....more

Paul Hastings LLP

FCA Puts Firms on Notice Over Anti-Money Laundering Shortfalls

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The FCA has provided feedback on its 2025 multi-firm review of customer due diligence (CDD), enhanced due diligence (EDD) and ongoing due diligence controls across various regulated sectors. The feedback relates to the...more

Hughes Hubbard & Reed LLP

Jeremy Paner Analyzes US Treasury’s Anti‑Money Laundering Action Against a Swiss Bank

Highlights - • Jeremy Paner highlights how FinCEN’s use of Special Measure Five against a Swiss bank signals a more aggressive anti money laundering enforcement posture. • Increased resources for FinCEN’s Enforcement...more

Bass, Berry & Sims PLC

FinCEN Advisory Warns Financial Institutions of Healthcare Fraud Targeting Medicare and Medicaid

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At the end of March, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a new Advisory urging financial institutions to heighten scrutiny of transactions potentially tied to healthcare fraud...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

DOJ Builds a Fraud Strike Force: What the New National Fraud Enforcement Division Means for White Collar Practice

In one of his first acts as Acting Attorney General, Todd Blanche issued a memorandum establishing the National Fraud Enforcement Division (“NFED”). The memo outlines what appears to be a structural reset of how the...more

BCLP

Navigating Geopolitical Uncertainty In The GCC: A Corporate Compliance And Risk Management Toolkit

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Geopolitical pressures across the Middle East are generating legal and regulatory exposure that many businesses have yet to fully map. Sanctions realignments, conflict-driven capital flows and supply chain fragility are...more

Womble Bond Dickinson

DOJ Launches New National Fraud Enforcement Division

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On April 7, 2026, Acting Attorney General Todd Blanche announced the establishment of the National Fraud Enforcement Division (“NFED”) as a centerpiece of the U.S. Department of Justice’s (“DOJ”) renewed fraud-enforcement...more

Holland & Knight LLP

Reformas al Reglamento de la Ley Antilavado en México

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Se publicó en México el 27 de marzo de 2026 el decreto que reforma el Reglamento de la Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (LFPIORPI). Este decreto consolida las...more

Skadden, Arps, Slate, Meagher & Flom LLP

Corporate Voluntary Self-Disclosure for the Southern District of New York

On February 24, 2026, the U.S. Attorney’s Office for the Southern District of New York (SDNY) announced a new corporate self-disclosure program (SDNY program) specific to the district that outlined a path for companies to...more

ArentFox Schiff

FinCEN’s New Whistleblower Program: A Game-Changer for AML and Sanctions Enforcement

ArentFox Schiff on

On April 1, the Financial Crimes Enforcement Network (FinCEN) submitted a Notice of Proposed Rulemaking proposing regulations to establish a formal Whistleblower Program under 31 U.S.C. § 5323....more

A&O Shearman

The Draft Money Laundering And Terrorist Financing (Amendment) Regulations 2026

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The draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were laid before UK Parliament, alongside a draft explanatory memorandum. The draft Regulations propose amendments to the Money Laundering,...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink Newsletter - February 2026 Updates

February 2026 saw heightened federal and state enforcement across a broad range of cryptocurrency fraud schemes, with regulators imposing substantial prison terms and restitution orders. Federal authorities sentenced a...more

A&O Shearman

UK FCA Annual Work Programme 2026/27

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The UK Financial Conduct Authority (FCA) has published its annual work programme for 2026/27 setting out its planned activity for the second year of its five-year strategy. ...more

Husch Blackwell LLP

OFAC Issues Guidance on Sham Transactions and Sanctions Evasion

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On March 31, 2026, the Office of Foreign Assets Control (“OFAC”) issued an advisory (the “Advisory”) regarding sham transactions and their use in evading US sanctions. OFAC described sham transactions as occurring when...more

White & Case LLP

White collar crime and the EU

White & Case LLP on

In the world of financial crime compliance, the first half of 2025 was dominated by news of the pause on enforcement of the Foreign Corrupt Practices Act (FCPA) by the US Department of Justice. As a result, more attention was...more

Bass, Berry & Sims PLC

FinCEN Update: Huge Penalty on Broker-Dealer for Willful AML, SAR, and Due Diligence Failures

On March 6, the Financial Crimes Enforcement Network (FinCEN) announced a historic $80 million civil money penalty against Canaccord Genuity LLC for willful violations of the Bank Secrecy Act (BSA) and its implementing...more

McGuireWoods LLP

$300 Million Reasons to Talk: FinCEN Proposes a Whistleblower Reward Program for AML and Sanctions Violations

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On March 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) submitted a Notice of Proposed Rulemaking (“NPRM”) for publication in the Federal Register that would, for the first...more

Ballard Spahr LLP

FinCEN Targets MBaer with Most Severe Section 311 Measure

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MBaer Merchant Bank AG (“MBaer”) was recently designated a “primary money laundering concern” by the U.S. Department of the Treasury’s Financing Crimes Enforcement Network (“FinCEN”) pursuant to Section 311 of the PATRIOT...more

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