Practice Mobile Menu Trigger Overview Experience Team Insights Subscribe to insights April 22, 2026 Client Update OFAC guidance on “sham transactions” erodes the Fifty Percent Rule for ownership OFAC’s recent “Guidance on Sham Transactions and Sanctions Evasion” suggests heightened due diligence obligations an... April 21, 2026 Client Update OFAC and FinCEN release proposed rule to implement the GENIUS Act FinCEN and OFAC have taken steps to implement the AML/CFT and sanctions compliance obligations under the GENIUS Act, the m... April 20, 2026 Articles & Books Deploying agentic AI in BSA and sanctions compliance Davis Polk counsel Kendall Howell authored “Deploying agentic AI in BSA and sanctions compliance” in ABA Risk and Comp... April 16, 2026 Client Update Proposed AML/CFT program rules provide new framework for AML/CFT supervision and enforcement FinCEN and the federal banking agencies released proposed AML/CFT program rules that largely reorganize the compliance req... April 16, 2026 Client Update Visual memo: Anti-money laundering and countering the financing of terrorism program proposed rules This visual memorandum provides a summary and overview of the Department of the Treasury’s proposed rules that would upd... April 7, 2026 Client Update FinCEN whistleblower program would offer financial incentives to report AML, sanctions violations FinCEN’s proposed rule would offer significant financial incentives to individuals who report corporate violations of an... March 25, 2026 Client Update FinCEN suspends enforcement of real estate reporting rule following district court vacatur FinCEN announced that it will not enforce reporting requirements under its residential real estate rule following the U.S.... February 20, 2026 Articles & Books Practical AI governance for community and midsize banks Davis Polk AML/CFT head Dan Stipano and counsel Kendall Howell authored “Practical AI governance for community and midsi... February 19, 2026 Client Update Venezuela sanctions update Over the past several weeks, the post-Maduro sanctions landscape in Venezuela has begun to take shape, with tightly contro... February 19, 2026 Client Update FinCEN streamlines CDD requirements, reducing compliance burden for covered financial institutions The Treasury Department’s Financial Crimes Enforcement Network continues its efforts to modernize the U.S. AML/CFT compl... Load More
April 22, 2026 Client Update OFAC guidance on “sham transactions” erodes the Fifty Percent Rule for ownership OFAC’s recent “Guidance on Sham Transactions and Sanctions Evasion” suggests heightened due diligence obligations an...
April 21, 2026 Client Update OFAC and FinCEN release proposed rule to implement the GENIUS Act FinCEN and OFAC have taken steps to implement the AML/CFT and sanctions compliance obligations under the GENIUS Act, the m...
April 20, 2026 Articles & Books Deploying agentic AI in BSA and sanctions compliance Davis Polk counsel Kendall Howell authored “Deploying agentic AI in BSA and sanctions compliance” in ABA Risk and Comp...
April 16, 2026 Client Update Proposed AML/CFT program rules provide new framework for AML/CFT supervision and enforcement FinCEN and the federal banking agencies released proposed AML/CFT program rules that largely reorganize the compliance req...
April 16, 2026 Client Update Visual memo: Anti-money laundering and countering the financing of terrorism program proposed rules This visual memorandum provides a summary and overview of the Department of the Treasury’s proposed rules that would upd...
April 7, 2026 Client Update FinCEN whistleblower program would offer financial incentives to report AML, sanctions violations FinCEN’s proposed rule would offer significant financial incentives to individuals who report corporate violations of an...
March 25, 2026 Client Update FinCEN suspends enforcement of real estate reporting rule following district court vacatur FinCEN announced that it will not enforce reporting requirements under its residential real estate rule following the U.S....
February 20, 2026 Articles & Books Practical AI governance for community and midsize banks Davis Polk AML/CFT head Dan Stipano and counsel Kendall Howell authored “Practical AI governance for community and midsi...
February 19, 2026 Client Update Venezuela sanctions update Over the past several weeks, the post-Maduro sanctions landscape in Venezuela has begun to take shape, with tightly contro...
February 19, 2026 Client Update FinCEN streamlines CDD requirements, reducing compliance burden for covered financial institutions The Treasury Department’s Financial Crimes Enforcement Network continues its efforts to modernize the U.S. AML/CFT compl...