United States: Money Laundering

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FinCEN Orders Exemptive Relief To Delay The Investment Adviser AML Rule By Two Years

Last year in September, we published an alert about the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) final rule, which would have imposed certain...

United States Government

WS

Winston & Strawn LLP

FinCEN Issues Order Delaying Effective Date Of Investment Adviser Rule

Following an earlier announcement on July 21, 2025, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"), on August 5, 2025, issued an Exemptive Relief Order ("Order") to delay for two years, from January 1, 2026 to January 1, 2028.

United States Government

AG

Akin Gump Strauss Hauer & Feld LLP

UK Supreme Court Sets A High Bar For Challenges To Sanctions Designations

On 29 July 2025, the Supreme Court handed down judgment in the combined appeals in Shvidler v Secretary of State for Foreign, Commonwealth and Development Affairs (‘Shvidler') and Dalston Projects Ltd and others v Secretary of State for Transport (‘Dalston Projects').

United States Litigation

D

Dechert

FinCEN Delays Implementation Date And Reopens AML/CFT Rule For Investment Advisers

On August 5, 2025, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued an order ("Order") exempting covered investment advisers from the requirements of its August 28, 2024...

United States Government

CM

Crowell & Moring LLP

U.S. Senate Introduces Act To Apply AML/BSA Laws To Art Dealers And Auction Houses

United States Government

BS

Ballard Spahr LLP

FinCEN To Postpone Effective Date And Reopen Anti-Money Laundering Rule For Investment Advisers

United States Government

GP

Goodwin Procter LLP

FinCEN Delays AML Requirements For Investment Advisers

United States Government

D

Dechert

GENIUS Act Establishes Regulatory Framework For Stablecoins

United States Technology

ST

Simpson Thacher & Bartlett

U.S. Department Of The Treasury To Delay Implementation Of The Investment Adviser Rule

United States Government

ST

Simpson Thacher & Bartlett

FINCEN Postpones AML/CFT Rules For Investment Advisers Until 2028 And Revisits Scope Of Such Rules

United States Government

BC

Bryan Cave Leighton Paisner

Investment Management & Funds Regulatory Update - July 2025

United States Government

DP

Davis Polk & Wardwell

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions To Counter Cartel-Linked Fentanyl Trade

United States Anti-trust

FL

Foley & Lardner

Anti-Money Laundering And Counter-Terrorism Financing

Worldwide Government

JD

Jones Day

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

United States Government

BS

Ballard Spahr LLP

Workplace Violence: Why Employers Can't Afford To Ignore The Warning Signs

United States Employment

OK

Offit Kurman

From 1925 To Today: How The FAA Transformed Dispute Resolution - The Importance Of Preserving The Core Values Of Arbitration

United States Litigation

J

JAMS

New Montana State Income And Property Taxes For 2025 & 2026

United States Tax

PB

Parsons Behle & Latimer

ALERT: Key Tax Provisions Provided For In "One Big Beautiful Bill Act"

United States Employment

DP

Dilworth Paxson LLP

Citizenship Updates: Nationwide Injunctions Affecting Birthright Citizenship Limited And New DOJ Priorities To Denaturalize U.S. Citizens

United States Immigration

Gs

Green and Spiegel

Direct Supervisory Powers Of The New European Anti-Money Laundering Authority

The Situation: The European Union Anti-Money Laundering ("AML") package includes Regulation (EU) 2024/1620 of the European Parliament and of the Council of May 31, 2024...

United States Government

JD

Jones Day

FinCEN Postpones Effective Date Of Investment Adviser AML Rule And Announces Intent To Revisit Its Scope

The IA AML Rule requires Covered Advisers to establish and maintain anti-money laundering/countering the financing of terrorism (AML/CFT) programs and comply with certain reporting and recordkeeping obligations under the BSA

United States Finance

GT

Greenberg Traurig, LLP

Privacy, Cyber & Data Strategy / White Collar, Government & Internal Investigations Advisory | GENIUS Act Establishes Federal Regulatory Oversight Of Global Stablecoin Industry

Our Privacy, Cyber & Data Strategy and White Collar, Government & Internal Investigations Teams examine how the GENIUS Act's framework for stablecoin issuers will impact the cryptocurrency sector.

United States Technology

AB

Alston & Bird

FinCEN Postpones Effective Date Of Anti-money Laundering Rules For Investment Advisers

FinCEN announced that it will postpone the effective date of a final rule that would impose anti-money laundering compliance requirements on investment advisers, indicating the agency will revisit and potentially...

United States Government

DP

Davis Polk & Wardwell

FinCEN's Cartel Crackdown On Three Mexican Financial Institutions: Implications For US Financial Transactions

United States Government

B

Bracewell

AML Reprieve For Investment Advisers

United States Government

KG

K&L Gates LLP

Risks Increase As U.S. Escalates Pressure Against Mexico With Regulatory Focus On The Financing Of Fentanyl Trafficking

United States Government

KI

K2 Integrity

Bank Secrecy Act Postponed For Investment Advisers And Exempt Reporting Advisers

United States Government

LS

Lowenstein Sandler

Treasury Postpones Effective Date Of Investment Adviser AML Rule; Signals Broader Reassessment Of Regulatory Framework

United States Government

AP

Anderson P.C.

Treasury To Delay Investment Adviser AML Rule To 2028, Announces Intent To Reconsider AML And CIP Rules

United States Government

PR

Proskauer Rose LLP

BREAKING: FinCEN Postpones Effective Date Of Investment Adviser AML Rule

United States Government

MB

Mayer Brown

FinCEN Postpones Effective Date Of AML/CFT Program Rule For Investment Advisers To 2028

United States Government

SR

Schulte Roth & Zabel LLP

FinCEN Postponement And Reopening Of Investment Adviser AML/CFT Rule

United States Finance

SJ

Steptoe LLP

Global Anti-Corruption Insights: Summer 2025

United States Criminal

AP

Arnold & Porter

BREAKING: FinCEN Postpones Effective Date Of Investment Adviser AML Rule

Earlier today, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering...

United States Government

MB

Mayer Brown

FinCEN Postpones Effective Date Of AML/CFT Program Rule For Investment Advisers To 2028

On July 21, 2025, the US Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") announced its intention to postpone...

United States Government

SR

Schulte Roth & Zabel LLP

FinCEN Postponement And Reopening Of Investment Adviser AML/CFT Rule

On July 21, 2025, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule adding certain...

United States Finance

SJ

Steptoe LLP

Global Anti-Corruption Insights: Summer 2025

With the return of President Donald Trump to the White House came a new approach to enforcement of the U.S. Foreign Corrupt Practices Act (FCPA).

United States Criminal

AP

Arnold & Porter

A Guide To Virtual IBANs And Their Regulation

United States Technology

AO

A&O Shearman

Focus On Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions With Special Measures, Restricting Their Access To U.S. Financial System

On June 25, 2025, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued orders (the "Orders") pursuant to the Fentanyl Sanctions Act and FEND Off Fentanyl Act...

United States Government

CM

Crowell & Moring LLP

FinCEN Uses "Special Measures" To Combat Fentanyl Money Laundering, Raising Concerns Around Targeted Mexican Financial Institutions

The Financial Crimes Enforcement Network aims to combat the fentanyl crisis by acting on the 2024 Fentanyl Sanctions Act and the FEND Off Fentanyl Act, which grant the agency wide and previously untapped authority.

United States Government

PC

Perkins Coie LLP

FinCEN Designates Three Mexican Financial Institutions Under New Section 311 Authority: First Use Of Expanded Powers Under FEND Off Fentanyl Act Prohibits All Funds Transmittals To Named Entities

On June 25, 2025, FinCEN issued three orders pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three Mexican financial institutions as institutions of "primary money laundering concern."

United States Government

MB

Mayer Brown

FinCEN Sanctions Three Mexican Financial Institutions—Unwary Transactions May Trigger Prohibited Conduct With Broad Legal Implications

On June 25, 2025, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued orders designating three Mexico-based financial institutions...

United States Government

DM

Duane Morris LLP

Landmark FinCEN Orders Prohibit Fund Transfers Involving Three Mexican Financial Institutions Based On Illicit Opioid Trafficking Concerns

United States Finance

ML

Milbank LLP

Three Banks Targeted By FinCEN In FEND Off Fentanyl Act Actions: What To Know

United States Criminal

LS

Lowenstein Sandler

Trump Administration Clears Nippon Steel Acquisition Of U.S. Steel After Biden Block

United States International

TT

Torres Trade Law, PLLC

The BSA's Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs In The Cayman Islands To Comply With The BSA

United States Government

LS

Lowenstein Sandler

DOJ Issues New FCPA Enforcement Guidelines

United States Criminal

N

Nossaman LLP

Client Alert: Back In Action: The Trump Administration Lifts "Pause" In Foreign Corrupt Practices Act Enforcement

United States Criminal

JB

Jenner & Block

FinCEN Issues Advisory On Iranian "Shadow Banking" Network

United States Finance

AP

Arnold & Porter

OFAC Imposes Largest-Ever Penalty On Nonbank Financial Institution For Egregious And Sustained Sanctions Violations—a $216M Warning To U.S. Fund Managers: Know Your Investors

Worldwide International

LS

Lowenstein Sandler

DOJ Adopts Risk-Based Approach In FCPA & White-Collar Enforcement Policy Shift

United States Criminal

PR

Proskauer Rose LLP

The Department Of Justice Announces New Guidelines For Foreign Corrupt Practices Act Investigations And Enforcements

United States Criminal

BI

Buchanan Ingersoll & Rooney PC

FDIC And Maryland End Joint Consent Orders Against Regional Bank

United States Government

SM

Sheppard Mullin Richter & Hampton

Best Practices For Businesses As Regulatory And Prosecutorial Focus On Trade-Based Money Laundering Expected To Increase

United States Government

BS

Boies Schiller Flexner

How To Spot Financial Red Flags That May Signal AML Exposure

United States Government

MG

MGO CPA LLP

The DOJ Announces Administration's Revised Corporate Enforcement Strategy

United States Criminal

B

BakerHostetler

A Refocused China Initiative: DOJ's New White Collar Enforcement Strategy

Worldwide Criminal

B

BakerHostetler

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Latest Videos

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Minutes On The Matter With Mike Beckwith: Federal Anti-Money Laundering Trends (Video)

DW

Dickinson Wright PLLC

Law Of Probability: Real-Money Games And Gambling (Video)

G

Gamma Law

Key Considerations For Financial Institutions Subject To The New AML Whistleblower Law (Video)

AP

Arnold & Porter

Current Developments And Looking Ahead In AML And Sanctions (Video)

AO

A&O Shearman

Our International Trade Team Comments On Recent Iran-Related Developments: Central Bank Sanctions, Humanitarian Trade, And Anti-Money Laundering Rules (Video)

HL

Hogan Lovells

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