On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing that it will extend the effective date of the final rule establishing anti-money laundering/countering the financing of terrorism program and suspicious activity report filing requirements for certain investment advisers and exempt reporting advisers (IA AML Rule), from Jan. 1, 2026, to Jan. 1, 2028.
On June 16, 2025, the Senate Finance Committee released its own version of the tax provisions of H.R. 1, entitled the “One Big Beautiful Bill Act,” which the U.S. House of Representatives passed on May 22, 2025. The full U.S. Senate is expected to debate the Senate Proposal in the days ahead, where additional changes may be made.
Continue Reading One Big Beautiful Bill Act – Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers Abroad
In late April, at the government’s request, an Indiana federal judge put a final end to the prosecution of an Indiana man for allegations that he engaged in unlicensed money transmission (and related tax offenses) in connection with his operation of a virtual currency exchange from 2009 to 2013.
Continue Reading Charges Dropped Against Early Cryptocurrency Exchange Operator
Federal and state “fair access” or “anti-debanking” laws and regulations have been evolving quickly over the last five years, closely tracking the changing U.S. political climate. These laws and regulations
Continue Reading US Fair Access and Anti-Debanking Laws: What to Expect Under the New Administration
This blog post highlights key trends in financial services litigation for 2025, including the rise in payments litigation, mass and international arbitration, and increased scrutiny on AML and KYC compliance. It also discusses changing regulatory risks, challenges from digital currencies, and the impact of new technologies and AI on legal disputes.
Continue Reading 5 Trends to Watch: 2025 Financial Services Litigation
On Sep. 4, 2024, FinCEN published a final rule (Final Rule) adding certain RIAs and ERAs (collectively, Covered Advisers) to the definition of “financial institution” under the regulations
Continue Reading FinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment Advisers
On Oct. 23, 2023, FinCEN published an NPRM that identifies international CVC mixing as “a class of transactions of primary money laundering concern,” and finds that imposing additional recordkeeping and
Continue Reading FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing
On April 18, 2023, Department of Commerce Assistant Secretary for Export Enforcement Matthew Axelrod issued a memorandum (Memorandum) that, while primarily focused on enforcement of export control restrictions, offered some
Continue Reading Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce Insights
On Dec. 15, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking implementing the provisions of the Corporate Transparency Act that
Continue Reading FinCEN Proposes Rule on Access to Beneficial Ownership Information
On Dec. 13, 2022, the Department of Justice announced that Danish global financial institution Danske A/S (Danske Bank) pled guilty and agreed to forfeit $2 billion to resolve an investigation
Continue Reading Danske Bank Pleads Guilty, Agrees to Pay More Than $2 Billion in Coordinated Resolution of Investigations into Fraud Related to Its Anti-Money Laundering Controls