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United States
This section covers AML/CTF initiatives by the US Treasury, US DoJ, OCC, FinCEN, SEC and other related US organisations.
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US FDIC and OCC propose a rule prohibiting supervisory actions based on reputation risk, ensuring institutions are not penalized for lawful activities or views – feedback by 6 Dec 2025
The proposed rule would prohibit these agencies from criticizing or taking adverse action against financial institutions based on reputation risk, and from instructing or encouraging institutions to close accounts or modify relationships due to a person or entity’s political, social, cultural, or religious views, or lawful business activities perceived as presenting reputation risk…
FinCEN invites comments on the renewal, without change, of BSA information collection requirements, obliging FIs to report accounts or transactions involving specified parties by 1 Dec 2025
FinCEN has proposed to renew, without change, its information collection requirements for sharing information between government agencies and financial institutions. This renewal aims to continue facilitating compliance with the Bank Secrecy Act and other financial crime prevention laws. The public comment period for this proposal ends on December 1, 2025…
FinCEN postpones the reporting requirements under the AML Regulations for Residential Real Estate Transfers Rule until 1 Mar 2026 – to reduce compliance burden and ensure effective regulation
This decision aims to reduce business burdens while maintaining effective regulation to protect the U.S. financial system from illicit activities….
US BIS issues an interim final rule extending export restrictions to entities 50%+ owned by listed or military-affiliated parties, with a 60-day temporary license – comments by 29 Oct
This change aims to close loopholes where affiliates of listed entities could previously circumvent restrictions. The rule also introduces a Temporary General License (TGL) permitting certain transactions involving non-listed foreign affiliates of listed entities, with the TGL set to expire 60 days after the rule’s filing date. Comments on the rule are invited and must be submitted within 30 days from the filing date…
US Treasury’s Financial Literacy and Education Commission meets to tackle rising payment fraud, requiring federal payments to transition to electronic methods under EO 14247 by 30 Sept 2025
Treasury Secretary Scott Bessent highlighted that this shift not only protects against fraud but also promotes financial literacy. Officials urged individuals still receiving paper checks to switch to electronic payments via GoDirect.gov or a dedicated helpline and warned the public to remain vigilant against government impersonation scams during the transition…
FinCEN publishes new guidance clarifying that banks may share cross-border transaction and customer information to strengthen AML/CFT efforts while keeping SARs strictly confidential
The guidance emphasizes that financial institutions may voluntarily exchange underlying factual and transactional data with foreign counterparts, provided such sharing does not reveal the existence of a SAR. It underscores that this discretion must be exercised in light of each institution’s risk profile, legal obligations, and the need to protect sensitive information.
US Treasury seeks public comments on implementing the GENIUS Act to regulate stablecoins while addressing potential illicit finance risks – with comments due by 20 Oct 2025
The GENIUS Act mandates the Treasury to develop regulations that foster innovation in payment stablecoins while mitigating potential illicit finance risks. The ANPRM invites public input, including data and information, to inform the development of these regulations. Comments are due by October 20, 2025…
FinCEN issues a notice proposing to postpone the effective date of its final AML and SAR filing rule for Investment Advisers, from 1 Jan 2026 to 1 Jan 2028
This follows an exemptive relief order issued on August 5, 2025, aimed at giving the investment adviser industry additional time to prepare for compliance with the AML rule…
US FINRA launches Crypto and Blockchain Education Program to equip member firms, aiming to bridge knowledge gaps, enhance compliance, and strengthen crypto fraud detection
As member firms increasingly engage with crypto assets and blockchains, the e-learning program will broaden industry knowledge and empower compliance professionals to combat crypto-related fraud. The program features application-based activities, scenarios, and self-assessment quizzes and covers a wide range of concepts, from basic terminology to fraud typologies and business activity considerations…
FinCEN reissues modified Geographic Targeting Order requiring MSBs to report cash transactions between $1,000 and $10,000 in selected border regions to combat Mexico-linked illicit activity
This measure replaces the earlier $200 threshold, introduces an extended compliance provision for newly covered MSBs until October 10, 2025, and strengthens law enforcement’s ability to cut off access to the U.S. financial system by drug cartels and other illicit actors…
FinCEN new Guidance encourages voluntary cross-border information sharing among FIs to better combat ML/TF, and fraud, while clarifying that SARs cannot be shared
The guidance clarifies that while SARs and related disclosures remain prohibited under the Bank Secrecy Act, institutions may share underlying transaction records, customer data, and other non-SAR information to strengthen detection of illicit finance. It also emphasises that such cross-border sharing is voluntary and creates no new regulatory obligations…
FinCEN issues Advisory and Financial Trend Analysis highlighting how Chinese ML networks are moving cartel-linked illicit funds through U.S. banks and informal transfer channels
From January 2020 to December 2024, FinCEN analysed 137,153 Suspicious Activity Reports, identifying approximately $312 billion in suspicious transactions linked to CMLN activity. These networks exploit individuals—including students, retirees, and others with PRC passports—who may unwittingly facilitate laundering through bulk cash deposits, mirror trading, trade-based laundering, shell companies…