United States: Money Laundering

Secretary of the Treasury Scott Bessent outlined the Trump administration's approach to economic statecraft in a recent speech, emphasizing the strategic use of American economic power to advance national security objectives. His remarks signal continued focus on sanctions enforcement, financial system integrity, and combating illicit finance networks while promoting reciprocity in international economic relationships.

The Federal Reserve has charted an independent course in revising anti-money laundering regulations for banks, notably excluding a key provision that would grant FinCEN oversight authority over enforcement actions. This divergence from the Treasury Department's unified regulatory approach raises critical questions about interagency coordination and the future of AML/CFT supervision. Governor Michael Barr's dissent highlights concerns about the undefined "significant or systemic" standard that will determine

FinCEN's updated Section 314(b) Fact Sheet clarifies that financial institutions may now share fraud-related information with other participating institutions under the USA PATRIOT Act's safe harbor protections. The guidance addresses long-standing concerns about confidentiality and scope, while confirming that information sharing extends to foreign financial institutions in certain circumstances and does not require identification of specific fraud proceeds.

The Trump Administration intensifies its crackdown on transnational scam networks with sweeping sanctions against the Prince Group, while renewed US-Iran hostilities threaten fragile diplomatic progress. As Washington expands its global enforcement reach from Southeast Asian fraud operations to Cuban regime networks, the geopolitical landscape shifts with cryptocurrency seizures, international cooperation, and strategic sanctions relief creating new compliance challenges for businesses navigating an increas

Texas and Colorado banking regulators entered into a joint consent order with a money transmitter over alleged deficiencies in its anti-money laundering compliance program, including late federal reporting, inadequate agent monitoring, and customer information safeguard failures. The company agreed to pay $200,000 in penalties and retain an independent compliance consultant without admitting the allegations.

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Bass, Berry & Sims attorneys Thad McBride and Jamie Parkinson co-authored an article for National Law Review highlighting recent proposed rulemaking from a busy Financial Crimes Enforcement Network (FinCEN).

The U.S. Department of State has designated two major Brazilian criminal organizations, Comando Vermelho and Primeiro Comando da Capital, as Specially Designated Global Terrorists and Foreign Terrorist Organizations.

On April 7, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a notice of proposed rulemaking (the FinCEN Proposed Rule)...