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 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
On Sept. 29, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule, effective Jan. 1, 2024, implementing the beneficial ownership information reporting
Continue Reading Beneficial Ownership Reporting Requirements: FinCEN Issues Final Rule for Implementation of Corporate Transparency Act
On Sept. 29, 2022, the Financial Industry Regulatory Authority (FINRA) released Regulatory Notice 22-20, alerting members to changes to the Sanctions Guidelines (Guidelines), effective immediately. The notice discusses
Continue Reading FINRA Releases Updated Guidelines and Sanctions for Securities Rule Violations
On Oct. 11, 2022, the U.S. Treasury Department announced that cryptocurrency exchange Bittrex Inc. had agreed to settle $53 million total in fines over allegations it violated sanctions and anti-money-laundering
Continue Reading Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering Violations
On July 14, 2022, the U.S. House of Representatives passed bipartisan legislation that, if passed by the Senate and signed into law, would expand the types of institutions required to
Continue Reading ENABLERS Act Proposes to Expand Definition of ‘Financial Institution’; Impose BSA/AML Requirements on Professional Service Providers
On Dec. 6, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on potential requirements
Continue Reading FinCEN Launches Rulemaking Process to Implement Reporting Requirements for Real Estate Sector
On Jan. 1, 2021, the U.S. Senate joined the House in voting to override President Trump’s veto of the National Defense Authorization Act of 2021 (NDAA), which includes several new
Continue Reading Implications for Art Dealers in Anti-Money Laundering Provisions of the National Defense Authorization Act of 2021