A federal court vacated FinCEN’s Anti-Money Laundering Regulations for Residential Real Estate Transfers, finding FinCEN exceeded its statutory authority under the Bank Secrecy Act.
FinCEN Proposes Reforms to AML/CFT Program Requirements
FinCEN published a proposed rule to reform anti-money laundering and countering the financing of terrorism program requirements for financial institutions under the Bank Secrecy Act.
Continue Reading FinCEN Proposes Reforms to AML/CFT Program Requirements
Compliance Deadline Approaches for FinCEN’s Residential Real Estate Reporting Requirements
Effective March 1, 2026, FinCEN’s Residential Real Estate Rule will impose streamlined reporting (the Real Estate Report) and recordkeeping requirements on certain persons involved in residential real estate closings and settlements (collectively, Reporting Persons).
Continue Reading Compliance Deadline Approaches for FinCEN’s Residential Real Estate Reporting Requirements
Deadline Quickly Approaching for Newly Covered MSBs To Comply with FinCEN’s Southwest Border GTO
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
FinCEN Postpones Effective Date of Investment Adviser AML Rule and Announces Intent to Revisit Its Scope
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.
Charges Dropped Against Early Cryptocurrency Exchange Operator
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 Warns US Financial Institutions of Bulk Cash Smuggling Risks from Mexico-Based Cartels
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.
FinCEN Issues Interim Final Rule Exempting Domestic Companies and US Beneficial Owners From Reporting Requirements
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.
Effective April 14: FinCEN GTO Requires MSBs Along US Southwest Border to Report Transactions in Currency of More than $200
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
CTA UPDATE: Enforcement Remains Suspended Despite U.S. Supreme Court Granting Stay of Preliminary Injunction
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