Financial Crimes Enforcement Network (FinCEN)

On June 30, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued its first-ever Anti-Money Laundering and Countering the Financing of Terrorism National Priorities (the “Priorities”). FinCEN was required to do this by the Anti-Money Laundering Act of 2020 (“AMLA”), enacted on January 1, 2021, as part of the National Defense Authorization Act of 2021. FinCEN

On April 5, 2021, the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed Rulemaking (ANPRM) in the Federal Register seeking public comment on 48 questions with respect to the implementation of the beneficial ownership reporting requirements in the Corporate Transparency Act (CTA) and the implementation of the related database maintenance use and

On March 9, 2021, the Financial Crimes Enforcement Network (FinCEN) published its first Notice related to one of the many changes made in the Anti-Money Laundering Act of 2020 (the AML Act), passed as part of the National Defense Authorization Act for Fiscal Year 2021, which we wrote about here. FinCEN’s guidance informs financial

On October 23, 2020, the Federal Reserve Board and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking that would amend the Bank Secrecy Act’s Recordkeeping Rule and Travel Rule regulations. The proposed changes would: (a) lower the threshold for covered cross-border transactions from $3,000 to $250, and (b) extend the

On January 1, 2021, the Senate followed the House and voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (NDAA). As is typical, the NDAA touched on a wide range of legal areas, including numerous new government contracts requirements, as well as a number of sanctions and export

On October 1, 2020, the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) each released advisories (the OFAC Advisory and the FinCEN Advisory) addressing financial crime-related risks associated with ransomware and ransomware payments. The OFAC Advisory focuses on the risk that ransomware attacks or payments may involve sanctioned persons

On September 16, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued an advanced notice of rulemaking (“ANPRM”) requesting comments on proposed regulatory changes under the Bank Secrecy Act (“BSA”) that aim to enhance the effectiveness of anti-money laundering (“AML”) programs.  The proposals reflect the recommendations of a working group within the Bank Secrecy Act Advisory

The Financial Crimes Enforcement Network (FinCEN) has issued two advisories to alert financial institutions to scams related to the COVID-19 pandemic, and has stated that it intends to continue to issue similar alerts.  The advisories, based on FinCEN’s analysis of COVID-19-related information obtained through Bank Secrecy Act (BSA) data, public reports, and law enforcement partners

On July 16, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an alert to financial institutions emphasizing a recent scam exploiting Twitter accounts to fraudulently solicit virtual currency payments.  The cyber threat actors involved in the scam compromised accounts of various public figures, organizations, and financial institutions in an attempt to solicit virtual currency payments

On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) issued helpful guidance on due diligence requirements for hemp-related businesses under the Bank Secrecy Act (BSA). The four-page guidance builds upon a December 3, 2019 joint statement on this topic issued by FinCEN, the Board of Governors of the Federal Reserve System, the Federal Deposit