This Summer, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advisory urging financial institutions to heighten their vigilance for risks tied to the unlawful employment of non-work-authorized individuals. The advisory highlights the increasingly prevalent role of labor brokers in facilitating fraudulent conduct and identifies several “red flags” that can alert banks
In May, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Alert FIN-2026-Alert002, warning financial institutions about the use of front companies, financial facilitators, and digital asset infrastructure by Iran’s Islamic Revolutionary Guard Corps (IRGC) to evade sanctions and launder proceeds. The Alert represents an escalation in U.S. government guidance concerning
President Trump’s May 19, 2026 executive order, Restoring Integrity to America’s Financial System, directs Treasury, FinCEN, the CFPB, and the federal banking agencies to reassess how financial institutions identify and manage risks associated with non-work authorized populations and related cross border financial activity. The order reflects a significant shift in federal expectations across
On April 30, 2026, the Financial Crimes Enforcement Network (“FinCEN”) published a notice and request for comment (the “Notice”) in connection with its renewal of Form 107, which Money Services Businesses utilize for registration and renewal purposes. FinCEN’s Notice proposes a renewal without change to Form 107, and the comment period remains open until June
On April 23, 2026, the Department of Justice announced charges against two Chinese Nationals, Huang Xing Shan and Jiang Wen Jie, for wire fraud, the seizure of $700 million in Cryptocurrency and the seizure of a Telegram Channel and 503 websites as part of the Department’s effort to combat foreign fraud schemes that target American
On April 8, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) issued a joint Notice of Proposed Rulemaking (NPRM) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The proposal would create a comprehensive anti‑money‑laundering/countering‑the‑financing‑of‑terrorism (AML/CFT) and sanctions compliance
On March 31, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an advisory on sham transactions, highlighting the compliance risks financial institutions must navigate when facilitating international property transactions.
What is a Sham Transaction?
OFAC defines a “Sham Transaction” as one in which a blocked person, typically operating
As part of the U.S. Department of Treasury’s efforts to modernize the U.S. anti-money laundering regulatory and supervisory framework, the Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would reform how financial institutions design and operate their anti-money laundering and countering the financing of terrorism (AML/CFT) programs. Though not a wholesale rebuild
Recently, a federal judge in the Eastern District of Texas vacated FinCEN’s residential real estate rule (the “Rule”) finding that the agency exceeded its statutory authority under the Bank Secrecy Act (the “BSA”). Flowers Title Companies, LLC v. Bessent, Case No. 6:25-cv-127 (E.D. Tex. Mar. 19, 2026). Since finalization in 2024, the Rule has
MBaer Merchant Bank AG (“MBaer”) was recently designated a “primary money laundering concern” by the U.S. Department of the Treasury’s Financing Crimes Enforcement Network (“FinCEN”) pursuant to Section 311 of the PATRIOT Act.
The Consequences
FinCen detailed its allegations against MBaer on February 26, 2026, in its Notice of Proposed Rulemaking (“NPRM”) where it