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FinCEN

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
Morgan Lewis

New York LLC Transparency Act to Take Effect January 1, 2026

Morgan Lewis on

The New York LLC Transparency Act, which imposes new disclosure requirements on limited liability companies (LLCs) formed in New York as well as foreign LLCs authorized to do business in New York, goes into effect on January...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

Bradley Arant Boult Cummings LLP on

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

Whiteford

Client Alert: New York LLC Transparency Act: What New York LLCs Need to Know Before 2026

Whiteford on

The New York Limited Liability Company Transparency Act (“NY LLCTA”), which was modeled after the Corporate Transparency Act (“CTA”), is set to take effect on January 1, 2026. The NY LLCTA, originally signed into law on...more

Parker Poe Adams & Bernstein LLP

Senate Republicans Introduce Bill Proposing to Raise Anti-Money Laundering Thresholds

Parker Poe Adams & Bernstein LLP on

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

Orrick, Herrington & Sutcliffe LLP

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

Orrick, Herrington & Sutcliffe LLP on

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

Nutter McClennen & Fish LLP

Nutter Bank Report: October 2025

Nutter McClennen & Fish LLP on

The Federal Reserve has issued guidance—including template term sheets—on the process for mutual banking organizations, such as mutual holding companies, to issue capital instruments that qualify as regulatory capital. The...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

Allen Barron, Inc.

FBAR Requirements as a U.S. Person for an Offshore Account

Allen Barron, Inc. on

What are your FBAR requirements as a U.S. person or taxpayer for an offshore account, group of accounts, property, or investment? The penalties for non-compliance with reporting offshore accounts, assets, and income are...more

Orrick, Herrington & Sutcliffe LLP

DOJ and Treasury act against Southeast Asian scam networks, seize $15B in bitcoin linked to pig-butchering scheme

Orrick, Herrington & Sutcliffe LLP on

On October 14, the DOJ announced the unsealing of an indictment charging a Cambodian national as the leader of a transnational criminal organization (TCO) that allegedly operated “forced-labor scam compounds” in Cambodia....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

Ballard Spahr LLP

FinCEN Bars Huione Group from Financial System

Ballard Spahr LLP on

On October 15, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a final rule under Section 311 of the USA PATRIOT Act that prohibits U.S. financial institutions from conducting business with the Cambodia-based...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

Snell & Wilmer

Heightened Government Enforcement Activity Against Foreign-Originated Fraud Schemes

Snell & Wilmer on

Over the past few months, the federal government has signaled concerted enforcement scrutiny of financial fraud that originates abroad and victimizes U.S. investors and consumers. This new focus involves numerous federal...more

Friling Law

OFAC Whistleblowing: Exposing Sanctions Violations Under U.S. Law

Friling Law on

The Office of Foreign Assets Control (OFAC) stands among the most influential arms of the U.S. Department of the Treasury, charged with administering and enforcing economic and trade sanctions that safeguard national...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

Troutman Pepper Locke on

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

Brownstein Hyatt Farber Schreck on

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

Morrison & Foerster LLP

The Anti-Money Laundering Quarterly

Morrison & Foerster LLP on

On July 9, 2025, money-transmission regulators for six states entered a coordinated consent order with Wise US, Inc. following a multistate examination to ascertain Wise’s compliance with applicable state and federal laws and...more

Allen Barron, Inc.

U.S. Taxpayers with Offshore Investments Should Be Wary of PFICs

Allen Barron, Inc. on

U.S. taxpayers with offshore investments should be wary of PFICs (Passive Foreign Investment Company). Many foreign nationals live and work in the United States. For those who invest in offshore companies that generate...more

Orrick, Herrington & Sutcliffe LLP

FinCEN seeks comment on proposed survey of compliance costs for fintechs

Orrick, Herrington & Sutcliffe LLP on

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

Orrick, Herrington & Sutcliffe LLP on

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

Friling Law

INTERPOL Green Notices: Legal Framework, Consequences, and Defense Strategies

Friling Law on

I. Introduction - The International Criminal Police Organization — better known as INTERPOL — is the backbone of global law enforcement cooperation, connecting 196 member countries in the pursuit of international justice....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

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