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
On March 10, 2026, FinCEN issued a renewed and expanded Geographic Targeting Order (GTO) imposing enhanced reporting and recordkeeping requirements on certain money services businesses (MSBs) operating along the Southwest border. According to FinCEN, the action is intended to support law enforcement efforts to disrupt money laundering and bulk‑cash movement tied to Mexico‑based drug cartels
At ETHDenver 2026, SEC Chairman Paul S. Atkins and Commissioner Hester M. Peirce outlined the agency’s current thinking on investor protection, innovation, and regulatory adaptation for cryptocurrencies and tokenized assets. Their conversation reflected both ongoing SEC priorities and the broader challenges that financial regulators face as technology continues to reshape capital markets.
Prioritizing Investor Protection
On February 13, 2025, FinCEN issued an order granting exceptive relief for covered financial institutions from certain Customer Due Diligence (“CDD”) requirements for new account openings. The exceptive relief is part of deregulation efforts, consistent with Executive Order 14192, “Unleashing Prosperity Through Deregulation,” and Section 6403(d) of the Corporate Transparency Act (the “CTA”).
What’s Covered
As a reminder, the Financial Crime Enforcement Network’s (FinCEN) Residential Real Estate rule (the “Real Estate Rule”) is effective March 1, 2026. The Real Estate Rule was originally to take effect December 1, 2025, but FinCEN’s subsequently announced a temporary exemptive relief, extending the effective date until March. We have previously blogged about the Real
In response to the continued rise of payment card skimming, the United States Secret Service conducted one of its most expansive enforcement efforts to date, launching a nationwide initiative aimed at identifying and removing illicit skimming devices before stolen data could be used for fraud.
What is Card Skimming and How Does it Work?
The
In December, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $3,500,000 civil penalty against Paxful, Inc. and Paxful USA, Inc. (“Paxful”), pursuant to a consent order.
Paxful is an exchanger of convertible virtual currencies (“CVC”), operating both a CVC wallet service and a marketplace for peer-to-peer (“P2P”) buyers and sellers of CVC.
On January 9, 2026, U.S. Treasury Secretary Scott Bessent announced a series of new federal actions focused on schemes to defraud federal aid programs. Treasury’s announcement follows a series of high-profile investigations involving alleged fraud tied to federally funded programs, such as the Feeding Our Future scheme to defraud the Federal Child Nutrition Program in
The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released its latest Financial Trend Analysis (FTA) this month, reporting data from banks and other financial institutions showing that, following a recent surge, the number of reported ransomware incidents and payment amounts dipped slightly in 2024. High-profile ransomware attacks frequently appear in the news and