FinCEN

On Sep. 8, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it issued a new Geographic Targeting Order (September GTO) that renewed and modified FinCEN’s GTO announced on March 11, 2025 (March GTO).
Continue Reading Deadline Quickly Approaching for Newly Covered MSBs To Comply with FinCEN’s Southwest Border GTO

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.

Continue Reading FinCEN Postpones Effective Date of Investment Adviser AML Rule and Announces Intent to Revisit Its Scope

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

FinCEN recently issued an alert to warn U.S. financial institutions, particularly depository institutions and money services businesses (MBSs), of the risks and red flags associated with bulk cash smuggling by Mexico-based drug cartels and other transnational criminal organizations.

Continue Reading FinCEN Warns US Financial Institutions of Bulk Cash Smuggling Risks from Mexico-Based Cartels

On March 21, 2025, FinCEN issued an interim final rule narrowing the scope of the CTA’s BOI Reporting Rule (Reporting Rule) to foreign reporting companies and foreign beneficial owners.

Continue Reading FinCEN Issues Interim Final Rule Exempting Domestic Companies and US Beneficial Owners From Reporting Requirements

The Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) located in 30 ZIP codes across California and Texas to, among other things, report and maintain records of cash transactions exceeding $200 (up to $10,000), and to verify the identity of persons presenting such transactions
Continue Reading Effective April 14: FinCEN GTO Requires MSBs Along US Southwest Border to Report Transactions in Currency of More than $200

On Jan. 23, 2025, the U.S. Supreme Court granted the U.S. government’s request for a stay (SCOTUS Order) of the nationwide preliminary injunction of the Corporate Transparency Act (CTA) issued

Continue Reading CTA UPDATE: Enforcement Remains Suspended Despite U.S. Supreme Court Granting Stay of Preliminary Injunction

A Texas district court has issued a nationwide preliminary injunction four weeks before a key Jan. 1, 2025, reporting deadline for the Corporate Transparency Act (CTA) that, while in effect

Continue Reading Texas Court Blocks CTA Nationwide 4 Weeks Before Key Reporting Deadline

On June 28, 2024, FinCEN issued a Proposed Rule to amend BSA regulations that prescribe the minimum requirements for AML/CFT programs for “financial institutions.” Financial institutions subject to AML/CFT program

Continue Reading FinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements