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
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
Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more
On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more
As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities...more
As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more
FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more
FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has announced that it is extending its Geographic Targeting Order (GTO) focused on trade-based money laundering schemes in South Florida. When the GTO...more