OFAC’s recent “Guidance on Sham Transactions and Sanctions Evasion” suggests heightened due diligence obligations and erodes the “bright line” distinction between ownership and ...
FinCEN and OFAC have taken steps to implement the AML/CFT and sanctions compliance obligations under the GENIUS Act, the most notable of which include compliance requirements applicable t...
FinCEN and the federal banking agencies released proposed AML/CFT program rules that largely reorganize the compliance requirements that were initially proposed in 2024 and introduce a ne...
This visual memorandum provides a summary and overview of the Department of the Treasury’s proposed rules that would update requirements for anti-money laundering and countering the fin...
FinCEN’s proposed rule would offer significant financial incentives to individuals who report corporate violations of anti-money laundering, sanctions and national security laws across ...
FinCEN announced that it will not enforce reporting requirements under its residential real estate rule following the U.S. District Court for the Eastern District of Texas’s decision to...
Over the past several weeks, the post-Maduro sanctions landscape in Venezuela has begun to take shape, with tightly controlled relief focused on the Venezuelan oil industry and broad sanc...
The Treasury Department’s Financial Crimes Enforcement Network continues its efforts to modernize the U.S. AML/CFT compliance framework, providing covered financial institutions excepti...
The Treasury Department’s Financial Crimes Enforcement Network launched a series of high-profile measures targeting alleged government benefits fraud in Minnesota. Treasury suggested th...
New Department of the Treasury guidance and the 2026 National Defense Authorization Act include a number of provisions affecting cross-border investment, including an update to the Outbou...