News & Analysis as of

Regulatory Requirements Suspicious Activity Reports (SARs)

White & Case LLP

“Unsubstantiated” suspicious transaction reports

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While financial institutions, on the one hand, are in the process of implementing and preparing to apply the fundamental amendments and changes that will take place in upcoming years by the EU AML Package—entering into force...more

Mayer Brown

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

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On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

A&O Shearman

UK Financial Intelligence Unit SARS report published

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The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...more

Walkers

Understanding the changes to the Proceeds of Crime Act: Insights from our conversation with the FRA

Walkers on

Businesses must be aware of the three core money laundering offences: concealing, arranging and acquiring (use and possession) criminal property. The FRA has issued a seven-day working period to consider all defence...more

K&L Gates LLP

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

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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

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

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

Alston & Bird

FinCEN Issues Geographic Targeting Order for U.S. Southwestern Border

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Our Financial Services and White Collar, Government & Internal Investigations Groups unpack the Financial Crimes Enforcement Network’s new geographic targeting order aimed at combatting money laundering and other illegal...more

Carlton Fields

Deadline Approaches for RIAs to Adopt AML Programs CIP Requirements Remain in Limbo

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On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). For...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for September 2024

Advisers Drafted by FinCEN for AML Duty, More Fines for E-Comm Retention Failures and a September Miracle, SEC Falls Back on Broken Windows Strategy, and a Refusal to Give Up on Private Fund Rules - FinCEN added to advisers’...more

Troutman Pepper Locke

Treasury Department Releases Semiannual Regulatory Agenda

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On August 16, the U.S. Department of the Treasury published its semiannual regulatory agenda in the Federal Register, detailing the agency’s upcoming regulatory actions and priorities. The agenda outlines the proposed, final,...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

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On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

Bilzin Sumberg

U.S. Transparency Updates

Bilzin Sumberg on

The United States has started with a bang for 2024 with respect to transparency initiatives. The initiatives affect real estate, financial and business sectors. This alert provides a brief overview of the developments in...more

Cadwalader, Wickersham & Taft LLP

FinCEN's Proposed Streamlined SAR -- The Real Estate Report

On February 16, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule addressing “Anti-Money Laundering Regulations for Residential Real Estate Transfers.” The proposed rule would, among other...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

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On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Ballard Spahr LLP

FinCEN Analysis Reveals $212 Billion in Identity-Related Suspicious Activity

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The Financial Crimes Enforcement Network (“FinCEN”) recently released a Financial Trend Analysis (“FTA”) focusing on identity-related suspicious activity.  The FTA was issued pursuant to section 6206 of the Anti-Money...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Expands Enforcement Measures To Address Fraud and Money Laundering

On 22 September 2022, the U.K. government introduced the Economic Crime and Corporate Transparency Act 2022. The new bill is currently navigating its way through the U.K. Parliament and is likely to receive royal assent in...more

Hogan Lovells

FinCEN provides regulatory relief to casinos, allowing “non-documentary” identification verification

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On October 19, 2021, FinCEN, the U.S. Government’s lead AML regulator, exercised its regulatory relief authority to allow casinos and card clubs to employ “non-documentary means” to verify patrons’ identity. The original...more

K2 Integrity

Human Trafficking and Banking: What Compliance Officers Need to Know

K2 Integrity on

Human trafficking is a global crisis that has an impact on lives around the globe. Over time, there have been many initiatives taken by governments and nonprofits to identify and help victims while promoting enhanced...more

Ballard Spahr LLP

Cyber-Enabled Financial Crime and Money Laundering

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Today we are very pleased to welcome guest blogger Moyara Ruehsen, PhD, CAMS, CFCS, who is an Associate Professor and Director of the Financial Crime Management Program at the Middlebury Institute of International Studies in...more

Orrick - On the Chain

FinCEN Sends Message to the Virtual Currency Industry: The Travel Rule Applies to You, Too

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FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Ballard Spahr LLP

Guilty Pleas Highlight Illicit Funneling of Chinese Cash to Casinos

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Government Suggests that Unusual Pleas are Just the Tip of an Iceberg - Chinese law generally prohibits its citizens from converting more than $50,000 in Chinese yuan into foreign currency in a year.  On Monday, two men...more

Stinson LLP

Missouri Financial Institutions Must Prepare for Impending Marijuana Banking Challenges

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In November 2018, Missouri voters passed Amendment 2, setting in motion state regulated medical marijuana. Over the last month, the Missouri Department of Health & Senior Services (DHSS) began approving license applications...more

Ballard Spahr LLP

AMA Updates AML Best Practices for AML Compliance

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AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more

Ballard Spahr LLP

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

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On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

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