Anti-Money Laundering
Miami Heat Guard Terry Rozier, former NBA player Damon Jones and others have been charged with wire fraud conspiracy and money laundering conspiracy for their purported participation in a scheme to use insider NBA information to profit from illegal betting activity. When announcing the charges, the Government stated, “[a]s alleged, the defendants turned professional basketball …
Continue reading “Money Laundering and Gambling Investigation Ensnares NBA Stars”
On October 23, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Financial Trend Analysis (“FTA”), identifying $9 billion of potential Iranian shadow banking activity in 2024, based on reporting from U.S. financial institutions. Treasury issues FTAs periodically with threat pattern and trend information derived from Bank Secrecy Act (BSA) …
Continue reading “FinCEN Releases Data Showing $9 Billion in Iranian Shadow Banking Activity”
On October 15, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a final rule under Section 311 of the USA PATRIOT Act that prohibits U.S. financial institutions from conducting business with the Cambodia-based Huione Group, a financial services conglomerate based in Phnom Penh, Cambodia. Huione Group is the parent company of, or otherwise controls, several subsidiaries, …
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On October 9, 2025, the Financial Crimes Enforcement Network (“FinCEN”) jointly issued updated Frequently Asked Questions (“FAQs”) with the Federal Reserve Board of Governors, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency, clarifying the circumstances under which financial institutions must file suspicious activity reports …
Continue reading “Suspicious Activity Reports – What New Guidance Means for Financial Institutions”
On October 9, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a renewal of its Geographic Targeting Order (“GTOs”), which require U.S. title insurance companies, including their subsidiaries and agents, to collect, retain, and report specified information regarding certain non-financed residential real estate transactions involving legal entities. The new GTO is effective from October 10, …
On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued three orders designating CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. (collectively, the “Designated Institutions”) as “financial institutions of primary money laundering concern.” These measures, taken under the FEND Off Fentanyl Act of 2024, …
We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) requirements to certain investment advisers. The Final Rule, which was set to become effective as of January 1 of next year, was the result of years …
Continue reading “FinCEN Delays And Intends To Revisit Investment Adviser Final Rule”
On July 23, 2025, Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Bill Cassidy (R-LA), Andy Kim (D-NJ), and David McCormick (R-PA), introduced the federal Art Market Integrity Act (the “Act”). The Act is bipartisan legislation that would require art dealers and auction houses to comply with anti-money-laundering and counter-terrorism financing regulations under …
On August 4, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice FIN-2025-NTC1 (the “Notice”) to address mounting concerns over regulatory risks related to convertible virtual currency (“CVC”) kiosks, also known as cryptocurrency ATMs. This action is part of a broader response to the rise in money laundering, fraud, and other financial crimes linked to …
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On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was deadlocked and unable to reach a verdict on the two more serious charges against Storm: conspiracy to commit money …