Designed for busy in-house counsel and compliance professionals, this newsletter summarizes key domestic and international anti-money laundering (AML) regulatory and enforcement developments from the past few months, with...more
On April 7, an Arizona-based Money Services Business (MSB) filed a complaint in the U.S. District Court for the District of Arizona challenging FinCEN’s March 2026 geographic targeting order (GTO) imposing additional...more
The U.S. District Court for the Eastern District of Texas vacated FinCEN’s new Residential Real Estate Rule on March 19. The rule created reporting requirements for certain non-financed transfers of residential real property...more
A new federal reporting requirement for certain residential real estate transfers that was to take effect on March 1 has been vacated....more
On March 10, 2026, FinCEN issued a renewed and expanded Geographic Targeting Order (GTO) imposing enhanced reporting and recordkeeping requirements on certain money services businesses (MSBs) operating along the Southwest...more
On February 27, FinCEN issued an order granting exemptive relief to certain banks from the recordkeeping and reporting requirements of a geographic targeting order (GTO) issued in Minnesota, which took effect February 12 ...more
Key Takeaways - FinCEN’s Geographic Targeting Order requires banks and money transmitters in Hennepin and Ramsey Counties, Minnesota, to report certain international funds transfers of $3,000 or more from Feb. 12 through Aug....more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) recently announced a sweeping enforcement operation targeting money services businesses (MSBs) operating along the Southwest U.S. border....more
On January 9, the U.S. Treasury announced a series of measures aimed at addressing alleged widespread government benefits fraud in Minnesota, purporting that billions of taxpayer dollars were lost to what the Treasury deemed...more
On January 9, 2026, the U.S. Department of Treasury issued a Geographic Targeting Order and FinCEN Alert to enhance financial activity reporting and combat fraud in Minnesota....more
On January 9, 2026, U.S. Treasury Secretary Scott Bessent announced a series of new federal actions focused on schemes to defraud federal aid programs. Treasury’s announcement follows a series of high-profile investigations...more
On December 22, 2025, Secretary of the Treasury Scott Bessent announced that the Financial Crimes Enforcement Network (FinCEN) will continue to target Money Services Businesses (MSBs) in 2026—with an increased use of...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
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
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
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 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
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 Financial Crimes Enforcement Network (FinCEN) issued a Southwest Border Geographic Targeting Order (GTO) aimed at Money Service Businesses (MSBs)[1]. This order is designed to enhance the monitoring and...more
In the last few weeks, the Financial Crimes Enforcement Network (FinCEN) has circulated several instructions focusing on money services businesses operating in the southwest United States, answering the current...more
On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more
On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...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
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...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