United States: Money Laundering

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Article
US Government Announces New Iran Sanctions Measures
The U.S. government has dramatically expanded Iran-related sanctions through new sectoral determinations, entity designations, and the suspension of key authorizations, while simultaneously targeting third-country financial institutions that facilitate Iranian transactions. These measures significantly broaden secondary sanctions risks across aviation, digital assets, gold, shipping, and technology sectors, marking a comprehensive escalation in economic pressure against Iran and its international networks.
United States Government
SA
Skadden, Arps, Slate, Meagher & Flom (UK) LLP
Article
Suspicious Activity Reports: What You CAN Disclose
Federal banking regulators and FinCEN have issued new guidance clarifying what financial institutions can tell customers about suspicious activity without violating Bank Secrecy Act confidentiality rules. The Joint Statement addresses the long-standing tension between SAR confidentiality requirements and the need for transparent customer communications about account restrictions, closures, and transaction denials.
United States Finance
Aa
Adams and Reese
Article
New Guidance Addresses SAR Confidentiality And Customer Communications
Banks and their employees face a difficult balancing act when discussing suspected fraud or money laundering activity with a customer on whose account activity the bank has filed a suspicious activity report (SAR). The bank must take practical steps to protect the customer and the institution (for example, verifying transactions, restricting account access, or requesting additional documentation) while strictly preserving SAR confidentiality.
United States Government
BS
Ballard Spahr LLP
Article
Weekly Sanctions Update: September 14, 2026
The Treasury Department intensifies economic pressure on Iran through Operation Economic Outcast, suspending aviation licenses and sanctioning dozens of entities while implementing a presumption of denial for Iran-related transactions. Meanwhile, new enforcement actions target Chinese cybercrime platforms, Ecuadorian terrorist organizations, and Israeli settlers, as Congress considers comprehensive Russia-Iran sanctions legislation.
Global Government
S
Steptoe LLP
Article
Operation Economic Outcast: Two Key Updates Two Weeks In
The Trump administration's Operation Economic Outcast represents an unprecedented escalation in Iran sanctions enforcement, threatening secondary sanctions against entire countries while expanding sectoral restrictions and targeting financial institutions globally. Two weeks into implementation, the campaign reveals a complex geopolitical landscape where major powers like China and Russia openly defy US demands, while European allies navigate conflicting legal obligations between supporting American
Global International
B
Bracewell
Article
FinCEN Clarifies That Banks May Discuss Fraud And Account Closures Without Disclosing SARs
FinCEN and federal banking agencies have issued a joint statement clarifying that banks can communicate with customers about fraud concerns and account closures without violating Suspicious Activity Report confidentiality rules. This guidance addresses confusion about what information banks can share while maintaining SAR secrecy, particularly in the context of the Administration's anti-debanking initiatives.
United States Finance
BS
Ballard Spahr LLP
Article
FinCEN Permanently Exempts U.S. Entities And Persons From Beneficial Ownership Reporting
The August 2026 final rule permanently exempts U.S. persons and domestic companies from Corporate Transparency Act beneficial ownership information reporting requirements, while maintaining obligations for foreign entities registered in the United States. This significant regulatory shift eliminates data exposure risks for U.S. persons and fundamentally reshapes compliance obligations for cross-border transactions and foreign portfolio companies.
United States Government
BS
Ballard Spahr LLP
Article
FinCEN Ends Corporate Transparency Act Requirement For U.S. Persons To Report Beneficial Ownership
The Financial Crimes Enforcement Network has issued a final rule fundamentally altering the Corporate Transparency Act's beneficial ownership reporting landscape. U.S. persons and domestic entities are now exempt from reporting requirements, while foreign entities registering to do business in the United States must continue reporting beneficial ownership information for foreign individuals. FinCEN plans to delete previously submitted beneficial ownership information from U.S. persons without requiring indi
United States Government
HL
Hogan Lovells Cadwalader
Article
The Final Chapter: FinCEN Permanently Eliminates BOI Reporting Requirements For US Companies And US Persons
The U.S. Treasury's Financial Crimes Enforcement Network has issued a final rule permanently removing beneficial ownership information reporting requirements for U.S. companies and persons under the Corporate Transparency Act. This comprehensive analysis examines the scope of the exemption, its impact on foreign entities registered in the United States, and the planned deletion of previously reported U.S. person data from FinCEN's database.
United States Government
MB
Mayer Brown
Article
FinCEN Final Rule Permanently Ends Beneficial Ownership Reporting Requirements For US Companies And US Persons
The U.S. Treasury's Financial Crimes Enforcement Network has issued a final rule permanently removing beneficial ownership information reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act. While this represents a significant rollback for domestic entities, foreign companies registered to do business in the United States may still face reporting obligations, creating a new bifurcated compliance landscape that businesses must carefully navigate.
United States Government
GT
Greenberg Traurig, LLP
Article
FinCEN, FDIC, OCC, And NCUA Issue Joint Advisory On Unlawful Employment Of Noncitizens
The US Treasury's Financial Crimes Enforcement Network has issued new guidance alerting financial institutions to fraud schemes involving the unlawful employment of non-work authorized individuals. The advisory identifies identity theft and payroll fraud typologies, providing 18 red flags to help banks detect suspicious activity connected to Immigration Reform and Control Act violations.
United States Government
SR
McDermott Will & Schulte
Article
Following The Money: FinCEN Maps The Financial Footprint Of Human Smuggling
FinCEN's latest Financial Trend Analysis reveals that financial institutions flagged nearly $5 billion in suspicious activity potentially linked to human smuggling between 2023 and 2025, with money services businesses filing 97% of reports but depository institutions accounting for 61% of the total value. The analysis identifies key red flags and typologies that institutions should incorporate into their transaction-monitoring systems, including patterns involving no verifiable familial connections, unusual
United States Finance
CM
Crowell & Moring LLP
Article
US Corporate Transparency Act Beneficial Ownership Reporting Permanently Curtailed
The US Financial Crimes Enforcement Network (FinCEN) has finalized significant changes to beneficial ownership reporting requirements under the Corporate Transparency Act, permanently exempting US companies and US persons from disclosure obligations. Non-US entities registered to do business in the US must still report their non-US beneficial owners, while FinCEN will delete previously reported information about US persons from its database.
United States Government
TL
Torys LLP
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