The Financial Crimes Enforcement Network (“FinCEN”) has proposed to revoke Banque Misr UAE’s (the “Bank”) correspondent banking access to U.S. financial institutions, finding that that the Bank is a financial institution operating outside of the U.S. and is of primary money laundering concern (the “Proposed Rule”).
This proposal was in direct response to current Iran
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
On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) renewed its Geographic Targeting Order (“GTO”) Imposing Recordkeeping and Reporting Requirements on Certain Financial Institutions in Minnesota. The GTO requires financial institutions located in Hennepin and Ramsey Counties, Minnesota, to “retain and report records of certain payments of $3,000 or
On July 13, a divided Ninth Circuit panel upheld a lower court order that barred enforcement of FinCEN’s border Geographic Targeting Order (“GTO”). The GTO would have forced money services businesses (“MSBs”) in 30 ZIP codes along the U.S.-Mexico border to report cash transactions of just over $200, a dramatic reduction from the longstanding $10,000
In an alert issued this July, FinCEN urged banks and other financial institutions to increase their focus on detecting, preventing, and reporting fraud schemes targeting federal student aid (“FSA”) programs. The alert provides specific red flags for identifying suspicious activity—and signals that regulators expect proactive compliance efforts.
The United States Department of Education (“ED”) has
On June 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “Alert”), alongside a press release, outlining efforts to combat fiscal fuel theft (known in Mexico as “huachicol fiscal”) along the U.S.-Mexico border. In simplest terms, fiscal fuel theft occurs when fuel is smuggled from the
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