In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to combat cartel activity by requiring heightened anti-money laundering reporting for money services business (MSBs) along the southwest border. The GTO—which went into effect
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A New Era for Digital Assets: The Impact of DOJ’s Shift Away from Regulation by Prosecution and Its Implications
In a significant policy shift, Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation By Prosecution,” on April 7, 2025, signaling a change in the Department of Justice’s (DOJ) approach to digital assets. The memorandum, outlines a move away from the previous administration’s enforcement efforts, which the memo called “reckless” and “ill conceived…
Anti-Money Laundering Aspects of the GENIUS Act
On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking, Housing, and Urban Affairs with a bipartisan 18-6 vote, paving the way for Congressional approval. The bill was introduced and sponsored by Senator…
Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation
On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in cryptocurrency activities. This recent directive, issued under Acting Comptroller Rodney Hood, rescinds the requirements set by Interpretive Letter 1179 from November…
FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels
We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of Justice (DOJ) as seen in United States Attorney General Pamela Bondi’s February 5, 2025 memorandum outlining the ways in which the DOJ will…
Recent Developments Raise Significant Questions about the Future of Regulation and Enforcement of Cryptocurrency
Recent developments in the world of crypto have come at a rapid pace to open 2025 not only signaling but, in some instances, explicitly declaring the Trump Administration’s intent to significantly relax or eliminate regulation and enforcement in the crypto markets. On January 23, 2025, President Trump signed an executive order with the goal of…
Department of the Treasury Suspends Enforcement of the Corporate Transparency Act and Plans to Revise Rule to Limit Scope
Does it matter if a law is valid if the Government refuses to enforce it? For months, we have watched (and blogged on) courts grappling with the constitutionality and enforceability of the Corporate Transparency Act (“CTA”). While, as we have blogged most recently here, courts have produced mixed returns on the validity of the…
Patriot Bank Enters Agreement with OCC to Address Regulatory Concerns
CTA Litigation Updates: Federal Judge in Maine Rules CTA is Justified, While Texas Judge Allows CTA Enforcement; FinCEN Announces Enforcement and Updated Reporting Deadline
Developments concerning the enforceability and enforcement of the CTA came at a rapid clip this week. As things stand, the government may enforce the CTA pending a Texas court appeal in Smith v. U.S. Department of the Treasury. FinCEN indicated its intent to enforce the CTA but provided reporting companies with a revised deadline to…
Attorney General Bondi Overhauls Justice Priorities
The new administration has signaled that the Department of Justice (“DOJ”) will significantly shift its approach to criminal corporate enforcement. Specifically, on February 5, 2025, newly-confirmed United States Attorney General Pamela Bondi issued a memorandum (the “Bondi Memo”) that outlined the ways in which the DOJ will aim to eliminate cartels and transnational criminal organizations…