Worldwide: Money Laundering

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Article
FinCEN Ends Corporate Transparency Act Requirement For U.S. Persons To Report Beneficial Ownership
The Financial Crimes Enforcement Network has issued a final rule fundamentally altering the Corporate Transparency Act's beneficial ownership reporting landscape. U.S. persons and domestic entities are now exempt from reporting requirements, while foreign entities registering to do business in the United States must continue reporting beneficial ownership information for foreign individuals. FinCEN plans to delete previously submitted beneficial ownership information from U.S. persons without requiring indi
United States Government
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Hogan Lovells Cadwalader
Article
The Final Chapter: FinCEN Permanently Eliminates BOI Reporting Requirements For US Companies And US Persons
The U.S. Treasury's Financial Crimes Enforcement Network has issued a final rule permanently removing beneficial ownership information reporting requirements for U.S. companies and persons under the Corporate Transparency Act. This comprehensive analysis examines the scope of the exemption, its impact on foreign entities registered in the United States, and the planned deletion of previously reported U.S. person data from FinCEN's database.
United States Government
MB
Mayer Brown
Article
OFAC's Largest-Ever CJNG Sanctions Raise The Stakes For Mexico Supply Chains
The U.S. Treasury's Office of Foreign Assets Control has launched its most extensive sanctions campaign against Mexico's Cartel de Jalisco Nueva Generación, targeting over 50 individuals and entities including the cartel's new leadership and legitimate business fronts. This enforcement action expands legal exposure for companies operating in Mexico's agricultural and commercial sectors, particularly those with supply chains in high-risk states. Understanding the implications of Foreign Terrorist Organi
United States Government
HK
Holland & Knight
Article
Reminder: 2026 OFAC Annual Report Of Blocked Property Due September 30, 2026
U.S. persons holding blocked property under OFAC sanctions programs face a critical September 30, 2026 deadline to file their Annual Report of Blocked Property. This comprehensive reporting obligation spans all OFAC sanctions programs and covers diverse asset types including bank accounts, securities, real estate, and digital assets. Understanding who must file, what constitutes blocked property, and how to properly submit reports through OFAC's reporting system is essential for compliance.
United States Government
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Crowell & Moring LLP
Article
FinCEN Issues Alert On Fraud Schemes Aimed At Federal Student Aid
The Treasury Department's Financial Crimes Enforcement Network has issued an alert urging financial institutions to detect and report suspicious activity connected to fraud schemes targeting federal student aid programs. Fraudsters are using stolen identities and synthetic identities to create "ghost students" and recruit "straw students" to unlawfully acquire billions in federal aid. The alert provides detailed red flags and reporting requirements to help financial institutions identify and prevent these s
United States Government
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Ballard Spahr LLP
Article
Beyond The Statutory Floor: What The MTRA’s Examination Manual Means For Money Transmitters
The Money Transmitter Regulators Association has released its comprehensive Examination Manual, providing unprecedented insight into state regulatory expectations for money transmitters. Beyond statutory compliance requirements, the manual reveals detailed supervisory benchmarks covering financial health metrics, governance structures, BSA/AML controls, and operational testing procedures that examiners may apply during reviews.
United States Finance
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McDermott Will & Schulte
Article
DOJ Announces First FCPA Deferred Prosecution Of 2026: Key Takeaways From Scoular’s $10 Million Resolution
The Scoular Company's recent FCPA enforcement action reveals how agricultural shipments crossing the U.S.-Mexico border became entangled in a bribery scheme involving Mexican officials and cartel associates. The case demonstrates DOJ's heightened focus on corruption that facilitates transnational criminal organizations, even when companies lack direct knowledge of cartel connections. What compliance measures should businesses implement to mitigate FCPA risks when operating with customs brokers and intermedi
United States Criminal
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Foley Hoag LLP
Article
Sanctions Update: July 20, 2026
The US has renewed its economic pressure campaign against Iran with multiple rounds of sanctions targeting weapons procurement networks, oil shipping operations, and financial facilitators, while simultaneously resuming military strikes and reinstating a blockade of the Strait of Hormuz. These actions follow the breakdown of a June memorandum of understanding and represent a parallel effort to compel Iranian concessions on nuclear and maritime issues, though the likelihood of success remains uncertain given
Worldwide Government
SJ
Steptoe LLP
Article
Weekly Sanctions Update: July 20, 2026
The Trump administration has resumed military strikes on Iran and expanded sanctions targeting oil-shipping networks and weapons procurement operations, while Congress advances sweeping Russia sanctions legislation that could impose unprecedented tariffs on major energy buyers. Meanwhile, the UK and EU coordinate new designations against Russian cyber operations and destabilizing activities, as global sanctions regimes expand to address conflicts in Sudan, Cuba, and beyond.
Worldwide Government
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Steptoe LLP
Article
Louisiana Enacts New Money Transmission Act, Largely Adopting Model Money Transmission Modernization Act
Louisiana has enacted House Bill 1230, replacing its Sale of Checks Act with a comprehensive money transmission licensing regime modeled after the Conference of State Bank Supervisors' Model Money Transmission Modernization Act. The new law establishes operational requirements for money transmitters, including NMLS licensing administration, financial safeguards, and authorized agent controls. Companies operating in Louisiana must navigate the transition period and prepare for new licensing processes and reg
United States Finance
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Greenberg Traurig, LLP
Article
Secretary Bessent Signals Continued Emphasis On Sanctions, Financial Integrity And Economic Statecraft In Recent Speech
Secretary of the Treasury Scott Bessent outlined the Trump administration's approach to economic statecraft in a recent speech, emphasizing the strategic use of American economic power to advance national security objectives. His remarks signal continued focus on sanctions enforcement, financial system integrity, and combating illicit finance networks while promoting reciprocity in international economic relationships.
United States Government
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Herbert Smith Freehills Kramer LLP
Article
Federal Reserve Follows (To A Degree) FinCEN And Other Banking Agencies In Proposing Sweeping AML/CFT Program Reforms
The Federal Reserve has charted an independent course in revising anti-money laundering regulations for banks, notably excluding a key provision that would grant FinCEN oversight authority over enforcement actions. This divergence from the Treasury Department's unified regulatory approach raises critical questions about interagency coordination and the future of AML/CFT supervision. Governor Michael Barr's dissent highlights concerns about the undefined "significant or systemic" standard that will determine
United States Finance
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WilmerHale
Article
FinCEN Clarifies The Scope Of Section 314(b) Information Sharing Includes Fraud
FinCEN's updated Section 314(b) Fact Sheet clarifies that financial institutions may now share fraud-related information with other participating institutions under the USA PATRIOT Act's safe harbor protections. The guidance addresses long-standing concerns about confidentiality and scope, while confirming that information sharing extends to foreign financial institutions in certain circumstances and does not require identification of specific fraud proceeds.
United States Government
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McDermott Will & Schulte
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