Davis Polk AML/CFT head Dan Stipano was quoted in MoneyLaundering.com discussing changes in AML compliance and enforcement in 2025.

“The Financial Crimes Enforcement Network’s decision in March to exempt tens of millions of entities from having to identify their beneficial owners pursuant to the Corporate Transparency Act perhaps marked the most significant shift in U.S. AML regulations this year,” Dan said.

The article noted that the rapidly evolving climate vis-a-vis sanctions and their role in U.S. foreign policy required anti-financial crime professionals to monitor trade negotiations and geopolitical dynamics.

“Trump-appointed regulators have figured out that the BSA and related authorities can be very useful in advancing their goals of attacking cartels and fentanyl trafficking,” Dan said. “We are increasingly seeing the Treasury Department use the BSA to advance the White House’s geopolitical agenda.”

Discussing the focus on debanking in 2025, Dan pointed out, “The OCC accused the nine largest banks subject to the agency’s supervision of unfair de-banking policies, but lenders typically exit or avoid relationships with customers based solely on a cost-benefit analysis.”

“I doubt you will find any bank that will admit it has engaged in unlawful debanking, but … I don’t know how acceptable that explanation is going to be to regulators,” he added. “It’s a no-win situation.”

“De-banking, De-regulation and Trump 2.0: US Compliance in 2025,” MoneyLaundering.com (December 17, 2025) (subscription required)

Copy link to share post