On October 5, 2026, the Financial Crimes Enforcement Network (“FinCEN”) announced that it is withdrawing two long-pending proposed rules aimed at convertible virtual currencies (“CVCs”).

The first notice of proposed rulemaking (“NPRM”) was a 2020 proposal that would have imposed recordkeeping, verification, and reporting requirements on certain transactions involving unhosted wallets. The second was a…

On October 1, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) Office of Foreign Assets Control (OFAC) took joint actions against the A7 Network, a global financial services infrastructure designed to evade sanctions, “to isolate Iran and its financial enablers,” as part of Operation Economic Outcast against Iran.

FinCEN NPRM

FinCEN issued a notice of…

The SEC on September 29, 2026, announced fraud charges against two clusters of entities alleged to have defrauded hundreds of retail investors, including many in the United States, out of at least $15.3 million through what the agency calls “investment confidence scams.” In a pair of complaints filed in the U.S. District Court for the…

On September 9, 2026, the U.S. Department of the Treasury announced that its Financial Crimes Enforcement Network (“FinCEN”) has identified approximately $17.5 billion in suspicious financial activity potentially linked to health care fraud.  The announcement accompanied the release of a new Financial Trend Analysis (“FTA”), which analyzed over 5,700 Bank Secrecy Act (“BSA”) reports filed…

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…