News & Analysis as of May 15, 2025

Currency Transaction Reports (CTR)

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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 -

FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

Ballard Spahr LLP on 4/29/2025

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

FinCEN Joins the Government-Wide Pursuit of Cartels

Morrison & Foerster LLP on 3/17/2025

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

FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML Program

Ballard Spahr LLP on 10/28/2024

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

FinCEN Announces First-Ever Enforcement Action Against Bitcoin Trader For Violations Of BSA

Fox Rothschild LLP on 4/24/2019

Last week, the Financial Crimes Enforcement Network (FinCEN) announced its first-ever civil penalty against a cryptocurrency exchanger for willful violations of the Bank Secrecy Act (BSA). According to the FinCEN Assessment...more

FinCEN Announces Civil Monetary Penalty for Virtual Currency Exchanger

Burr & Forman on 4/23/2019

On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) announced its first enforcement action against a peer-to-peer virtual currency exchanger....more

The U.S. Casino and Gaming Industry: AML/BSA Regulation and Enforcement

Ballard Spahr LLP on 7/17/2018

As we blogged yesterday, British Columbia’s (“B.C.”) Attorney General David Eby recently released an independent and very detailed report examining money laundering in B.C.’s gaming industry and providing 48 recommendations...more

FinCEN Announces First Card Club AML Enforcement Action

McGuireWoods LLP on 1/12/2016

Just in time for Christmas, the Financial Crimes Enforcement Network (FinCEN), the financial industry (including casinos and card clubs) regulator, announced its first-ever enforcement action against a card club, California’s...more

Investment Management Update - October 2015

Ballard Spahr LLP on 10/15/2015

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers

The Volkov Law Group on 9/8/2015

FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...more

AML and Investment Advisers: Understanding FinCEN's New Anti-Money Laundering Rules

BakerHostetler on 9/3/2015

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed rulemaking that would require registered investment advisers, including certain hedge funds and asset managers, to establish anti-money laundering...more

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