The Financial Crimes Enforcement Network (“FinCEN”) has proposed to revoke Banque Misr UAE’s (the “Bank”) correspondent banking access to U.S. financial institutions, finding that that the Bank is a financial institution operating outside of the U.S. and is of primary
Latest from Money Laundering Watch
New Guidance Addresses SAR Confidentiality and Customer Communications
Banks and their employees face a difficult balancing act when discussing suspected fraud or money laundering activity with a customer on whose account activity the bank has filed a suspicious activity report (SAR). The bank must take practical steps to
FinCen Renews its Focus on Minnesota
On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) renewed its Geographic Targeting Order (“GTO”) Imposing Recordkeeping and Reporting Requirements on Certain Financial Institutions in Minnesota. The GTO requires financial institutions located in Hennepin
Ninth Circuit Blocks FinCEN’s Border Geographic Targeting Order
On July 13, a divided Ninth Circuit panel upheld a lower court order that barred enforcement of FinCEN’s border Geographic Targeting Order (“GTO”). The GTO would have forced money services businesses (“MSBs”) in 30 ZIP codes along the U.S.-Mexico border
FinCEN Asks Banks to Step Up Efforts at Detecting Student Aid Fraud
In an alert issued this July, FinCEN urged banks and other financial institutions to increase their focus on detecting, preventing, and reporting fraud schemes targeting federal student aid (“FSA”) programs. The alert provides specific red flags for identifying suspicious activity—and
FinCEN Alert: BSA Compliance Implications Related to the Mexican Cartel’s Fiscal Fuel Scheme
On June 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “Alert”), alongside a press release, outlining efforts to combat fiscal fuel theft (known in Mexico as “huachicol fiscal”) along the
Red Flags for Fraud: FinCEN issues advisory on detecting unlawful employment practices
This Summer, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advisory urging financial institutions to heighten their vigilance for risks tied to the unlawful employment of non-work-authorized individuals. The advisory highlights the increasingly prevalent role of
FinCEN Alert: AML Compliance Implications of IRGC Sanctions Evasion and Illicit Finance
In May, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Alert FIN-2026-Alert002, warning financial institutions about the use of front companies, financial facilitators, and digital asset infrastructure by Iran’s Islamic Revolutionary Guard Corps (IRGC) to
Executive Order Signals Major Shift in Federal Expectations for AML, Customer Identification, and Credit Underwriting
President Trump’s May 19, 2026 executive order, Restoring Integrity to America’s Financial System, directs Treasury, FinCEN, the CFPB, and the federal banking agencies to reassess how financial institutions identify and manage risks associated with non-work authorized populations and related
Executive Order Signals Federal Shift on Fintech Regulation
President Trump issued Executive Order 14405 (the “Order”) on May 19, 2026 titled Integrating Financial Technology Innovation into Regulatory Frameworks. The Order directs federal financial regulators to review and update regulations, guidance, and supervisory practices to support financial technology innovation