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Money Laundering Watch

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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 labor brokers in facilitating fraudulent conduct and identifies several "red flags" that can…

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 evade sanctions and launder proceeds. The Alert represents an escalation in U.S. government…

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 cross border financial activity. The order reflects a significant shift in federal expectations across…

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 and reduce barriers to entry for non‑bank fintech firms. It follows earlier actions…

FinCEN Notice and Request for Comment on MSB Registration Form

On April 30, 2026, the Financial Crimes Enforcement Network ("FinCEN") published a notice and request for comment (the "Notice") in connection with its renewal of Form 107, which Money Services Businesses utilize for registration and renewal purposes. FinCEN's Notice proposes a renewal without change to Form 107, and the comment period remains open until June 29, 2026. The Bank Secrecy Act ("BSA")…

Scam Center Strike Force Targets Southeast Asian Scam Centers

On April 23, 2026, the Department of Justice announced charges against two Chinese Nationals, Huang Xing Shan and Jiang Wen Jie, for wire fraud, the seizure of $700 million in Cryptocurrency and the seizure of a Telegram Channel and 503 websites as part of the Department's effort to combat foreign fraud schemes that target American citizens. Huang and Jiang oversaw a cryptocurrency investment…

Treasury Unveils OCCIP Cyber Initiative for Digital Asset Firms

Last month, the U.S. Department of the Treasury announced a new cybersecurity information‑sharing initiative led by its Office of Cybersecurity and Critical Infrastructure Protection (OCCIP). The program is designed to give eligible U.S. digital asset firms access to the same actionable cyber‑threat information Treasury already provides to traditional financial institutions. According to Treasury,…

Treasury’s Proposed Rule Brings Stablecoin Issuers into the BSA Framework

On April 8, 2026, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) issued a joint Notice of Proposed Rulemaking (NPRM) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The proposal would create a comprehensive anti‑money‑laundering/countering‑the‑financing‑of‑terrorism…

OFAC Issues Advisory Warning on Sham Transactions

On March 31, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued an advisory on sham transactions , highlighting the compliance risks financial institutions must navigate when facilitating international property transactions. What is a Sham Transaction? OFAC defines a "Sham Transaction" as one in which a blocked person, typically operating through proxies…

FinCEN Proposes Rule to Increase Whistleblower Incentives

FinCEN has published a Notice of Proposed Rulemaking ("NPRM") that would formalize and expand its whistleblower program, offering potentially substantial financial payouts to whistleblowers reporting certain financial crimes. According to FinCEN's announcement , this initiative is designed to incentivize and protect individuals who report violations of major financial crime laws-specifically, the…