News & Analysis as of

Anti-Money Laundering Suspicious Activity Reports (SARs)

Mayer Brown

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

Mayer Brown on

On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

A&O Shearman

UK Financial Intelligence Unit SARS report published

A&O Shearman on

The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...more

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

Troutman Pepper Locke on

In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

WilmerHale

SEC Shouldn't Complicate Broker-Dealers' AML Compliance

WilmerHale on

The U.S. Securities and Exchange Commission's recent anti-money laundering enforcement actions reflect a number of trends and developments, but one positive and one negative trend stand out. Originally published in Law360...more

Walkers

Understanding the changes to the Proceeds of Crime Act: Insights from our conversation with the FRA

Walkers on

Businesses must be aware of the three core money laundering offences: concealing, arranging and acquiring (use and possession) criminal property. The FRA has issued a seven-day working period to consider all defence...more

K&L Gates LLP

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

K&L Gates LLP on

On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more

Alston & Bird

FinCEN Issues Geographic Targeting Order for U.S. Southwestern Border

Alston & Bird on

Our Financial Services and White Collar, Government & Internal Investigations Groups unpack the Financial Crimes Enforcement Network’s new geographic targeting order aimed at combatting money laundering and other illegal...more

Buchalter

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

Buchalter on

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

DLA Piper

FinCEN’s Geographic Targeting Order Increases Reporting Obligations for Money Services Businesses Located Near the United...

DLA Piper on

On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Europol Published Practical Guide for Cooperation Between Financial Institutions and Investigative Authorities

Public-private partnerships across the world between financial institutions, financial intelligence units and investigative authorities have laid the foundation to advance criminal investigations. However, there is further...more

K&L Gates LLP

Lessons From 2024 Anti-Money Laundering Enforcement Actions

K&L Gates LLP on

In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more

Carlton Fields

Deadline Approaches for RIAs to Adopt AML Programs CIP Requirements Remain in Limbo

Carlton Fields on

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). For...more

White & Case LLP

A call to arms: The FCA highlights the ongoing risk of money laundering through the capital markets

White & Case LLP on

The UK's capital markets are a vital economic driver, and also a significant source of money laundering risk. This is a difficult area of risk for regulators and law enforcement to understand and tackle, but progress is being...more

McDermott Will & Emery

The High Cost of Noncompliance: Making Sense of BitMEX’s $100 Million AML Penalty

McDermott Will & Emery on

On January 15, 2025, BitMEX, a Seychelles-registered crypto exchange, was fined $100 million in connection with a previously entered guilty plea to criminal violations of US anti-money laundering (AML) laws. The penalty...more

Sheppard Mullin Richter & Hampton LLP

FDIC Enforcement Spotlights Deficiencies in Kansas Bank’s Anti-Money Laundering Program

On December 27, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a notice of assessment of a civil money penalty against a Kansas-based bank. The action, originally brought in November, imposed a $20.4 million...more

Morgan Lewis

Five Developments Family Offices Are Watching in 2025

Morgan Lewis on

As family offices continue to adapt to economic, financial, and technological changes, several ongoing developments are giving family offices plenty consider heading into 2025, including gift and estate tax exemptions, which...more

Foodman CPAs & Advisors

Deepfake Media FinCEN Fraud Alert

On 11/13/24, FinCEN issued an alert aimed at assisting financial institutions in recognizing fraudulent schemes linked to the utilization of deepfake media generated by generative artificial intelligence (GenAI) tools. The...more

DLA Piper

SEC Enforcement Actions Highlight Anti-Money Laundering Reporting Focus for Financial Gatekeepers

DLA Piper on

The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more

Freiberger Haber LLP

Enforcement News: Broker-Dealers Settle Charges for Filing Deficient SARs

Freiberger Haber LLP on

The Bank Secrecy Act (“BSA”) and implementing regulations promulgated by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) require that broker-dealers file a suspicious activity report (SAR”) with...more

Davis Wright Tremaine LLP

FinCEN Warns of Criminal Use of Deepfake Technology to Circumvent Controls

Generative artificial intelligence (AI) holds tremendous promise for financial institutions and their customers. But that promise comes with potential peril, as highlighted in a recent alert issued by the U.S. Treasury...more

Foodman CPAs & Advisors

TD Bank gets $1.3 Billion Penalty from FinCEN

On 10/10/24, FinCEN assessed a record $1.3 billion penalty against TD Bank for BSA violations. This unprecedented penalty should function as a cautionary message and a warning to all financial institutions. All financial...more

Ballard Spahr LLP

FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML Program

Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”).  The Consent Order describes Lake...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 4- Watergate, Actual Knowledge and Conscious Indifference

Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to...more

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