Two recent developments signal that momentum is building in Washington to recalibrate Bank Secrecy Act (BSA) reporting to produce higher‑value intelligence with less compliance friction. First, on October 9, 2025, the Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators issued joint guidance in the form of Suspicious Activity Report (SAR) FAQs clarifying several
Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises flexibility for banks and fintech companies. The exemption allows certain financial institutions to collect a taxpayer identification number (TIN) from a reliable third-party source
In a historic move that signals a new era in the fight against illicit opioid trafficking and money laundering, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued its first-ever orders under the newly enacted Section 2313a of the Fentanyl Sanctions Act, as amended by the FEND Off Fentanyl Act. These
The U.S. real estate market has long been a cornerstone of the American dream—a path to stability, investment, and generational wealth. But at the margins, that same market has also provided an opportunity for illicit actors who exploit all-cash deals to quietly launder dirty money into legitimate assets. Recognizing this vulnerability, in August 2024, the
The Trump administration remains focused on countering Mexican cartels and other Latin American transnational criminal organizations (TCOs). Since designating eight TCOs as foreign terrorist organizations (FTOs), the Financial Crimes Enforcement Network (FinCEN) and Department of Justice (DOJ) have issued alerts and prosecutorial guidance respectively reinforcing the administration’s whole-of-government approach to countering this threat. As with
On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The GTO significantly lowers the Currency Transaction Reports (CTR) threshold from $10,000 to $200 for money service businesses (MSBs) operating in 30 zip codes across
On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s criminal guilty plea to conspiracy to launder hundreds of millions of dollars in drug cartel cash overshadowed a contemporaneous enforcement action
On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy Act (BSA) violations. When combined with agreements with the Federal Reserve, Office of the Comptroller of the Currency (OCC), and
Mortgage companies must maintain a heightened level of vigilance when it comes to preventing mortgage fraud. The incidence of fraud attempts targeting mortgage companies continues to rise, prompting decisive action against this threat. In a criminal complaint filed on April 23, 2024, in the U.S. District Court for the District of New Jersey, the
The heavily publicized announcement by New York federal prosecutors of the first-ever charges for insider trading in digital assets — non-fungible tokens, or “NFTs” in particular — is a significant but somewhat confusing development for the crypto community and beyond. There is nothing novel about applying well-established law to the abuse of confidential, insider information