News & Analysis as of

Suspicious Activity Reports (SARs)

King & Spalding

Venezuela Business Risks and Regulations

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The Trump Administration’s removal of former Venezuelan president Nicolás Maduro and recent announcements regarding the development of natural resources in Venezuela portend the United States’ renewed focus on the Western...more

Cooley LLP

Disclosure: How the English Courts Balance Comity, Risk of Foreign Sanctions and the Fair Disposal of Proceedings

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The Court of Appeal’s judgement in Various Claimants v. Standard Chartered plc is a significant decision on whether an English court may compel disclosure of documents that are confidential under foreign regulatory regimes –...more

Goodwin

FinCEN Issues Final Rule to Postpone Effective Date of Investment Adviser Rule to 2028

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Welcome to Goodwin’s Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking....more

Orrick, Herrington & Sutcliffe LLP

Treasury targets alleged Minnesota benefits fraud in new set of actions

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

Ballard Spahr LLP

FinCEN Imposes $3.5 Million Civil Penalty Against Paxful for BSA Violations

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In December, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $3,500,000 civil penalty against Paxful, Inc. and Paxful USA, Inc. (“Paxful”), pursuant to a consent order. Paxful is an...more

Katten Muchin Rosenman LLP

FinCEN Finalizes 2028 Compliance Date for Adviser AML Programs

On December 31, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a two‑year delay of the effective date for the anti-money laundering/counter-financing of terrorism (AML/CFT)...more

Proskauer - Regulatory & Compliance

FinCEN Finalizes Two‑Year Delay of the Investment Adviser AML Rule; Reaffirms Intent to Further Review and Tailor the Rule, and to...

FinCEN has now adopted its previously‑proposed two‑year delay in the effective date for the investment adviser AML rule (including the requirements to establish AML programs and file SARs) until January 1, 2028. FinCEN...more

Winthrop & Weinstine, P.A.

Treasury Issues Geographic Targeting Order to Banks in Hennepin and Ramsey Counties and FinCEN Alert to Combat Fraud in Minnesota

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

Ballard Spahr LLP

Treasury Targets Fraud: Heightened Bank Compliance Risks

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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

Orrick, Herrington & Sutcliffe LLP

FinCEN announces border-focused operation targeting BSA/AML non-compliance

On December 22, FinCEN announced a multi-tiered operation targeting more than 100 money services businesses (MSBs) operating along the southwest border for potential noncompliance with BSA/AML regulations. ...more

Winstead PC

FinCEN’s New AML/CFT Rules for Investment Advisers - Postponed

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The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury (the “Treasury”), issued a final rule (the “Final Rule”), adding investment advisers to the definition of “financial...more

Morrison & Foerster LLP

FInCEN Hits Pause: No AML Rule for Investment Advisers Until 2028

On December 31, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) issued a final rule formalizing its previously announced intention to reassess the specific requirements...more

McGuireWoods LLP

FinCEN Announces Data-Driven Operation Targeting Southwest Border MSBs

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On December 22, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a multifaceted data-driven operation to address potential money laundering, focused on more than 100 U.S....more

Mayer Brown

Virtual Currency Exchange Pleads Guilty to Criminal Charges Related to Anti-Money Laundering Violations and Pays Multi-Million...

Mayer Brown on

On December 9, 2025, the US Department of Justice (“DOJ”) announced a guilty plea by a peer-to-peer convertible virtual currency exchange (the “CVC Exchange”) for conspiring to: (i) violate the Travel Act; (ii) operate an...more

Ballard Spahr LLP

Has Ransomware Peaked? FinCEN Data Shows Slight Downward Trend In Incidents.

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The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released its latest Financial Trend Analysis (FTA) this month, reporting data from banks and other financial institutions showing that, following...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Publishes First Set of Compliance Considerations in Parallel Civil and DOJ Enforcement Actions Against Crypto Company...

For the first time, FinCEN’s press release announcing an enforcement action includes a section describing key “Compliance Considerations” arising from the case. This section mirrors an identically titled section that has for...more

Sheppard Mullin Richter & Hampton LLP

FinCEN Assesses $3.5 Million Penalty Against Virtual Asset Platform for Alleged BSA Violations

On December 9, FinCEN announced a consent order imposing a $3.5 million civil money penalty on a peer-to-peer virtual asset trading platform, alleging willful violations of the Bank Secrecy Act. FinCEN alleged that the...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Fines Virtual Currency Platform $3.5M for BSA Violations Tied to Illicit Activity

On December 9, FinCEN announced a consent order levying a $3.5 million civil money penalty against a peer-to-peer virtual currency trading platform for willful BSA violations. FinCEN alleged the company facilitated more than...more

Herbert Smith Freehills Kramer

Compliance Crossroads: Managing Privacy Requests And Tipping Off Risks As An AML/CTF Reporting Entity

Reporting entities are already familiar with the real challenges that can arise when seeking to meet their customer due diligence and ML/TF risk management obligations without engaging in “tipping off”. While recent changes...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – December 2025 # 2

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On December 5, the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) jointly rescinded the 2013 Interagency Guidance on Leveraged Lending and the 2014 FAQs, citing that the...more

Ankura

The Cinderella Effect: Transforming Quality Control in Financial Crime Compliance with AI

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Let us say what compliance officers whisper in hallways but rarely commit to writing: Quality control (QC) in financial crime has been the organizationally orphaned stepchild for decades — not the kind that gets sympathy, but...more

Orrick, Herrington & Sutcliffe LLP

FinCEN issues alert on cross-border fund transfers for suspicious activity reports

On November 28, FinCEN issued an alert as part of Treasury’s efforts to combat exploitation of the U.S. financial system by individuals without legal status seeking to remit potentially illicit funds. ...more

Ballard Spahr LLP

U.S. Government Launches Inter-Agency Effort to Combat Online Cryptocurrency Fraud Schemes

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While the Department of Justice (DOJ) has retreated from certain cryptocurrency enforcement matters, it remains keenly focused on protecting cryptocurrency investors from fraud. To that end, on November 12, 2025, the DOJ and...more

Ankura

The Emperor's New Clothes? Debunking Financial Crime Risk Appetite Statements

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Much like the tale of "The Emperor's New Clothes," where truth is clouded by fear and conformity, organisations encounter similar obstacles in developing their Financial Crime (FC) Risk Appetite Statements (RAS). This paper...more

Bradley Arant Boult Cummings LLP

FinCEN’S New Real Estate Reporting Rule: Historical Context, Compliance Requirements, Legal Challenges and What ACMA Members Need...

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

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