Consistent with EO 14178, FinCEN issued a request for comment required by the GENIUS Act on innovative or novel methods, techniques, or strategies that regulated financial institutions use, or could potentially use, to detect illicit activity involving digital assets (Aug. 18, 2025).

FinCEN issued an order exempting covered investment advisers from all requirements of its Investment Adviser Rule until January 1, 2028 and announcing intention to issue a notice of proposed rulemaking to propose a new effective date for the Rule (Aug. 5, 2025).

FinCEN announced its intention to postpone the effective dates and reopen its Investment Adviser Rule (July 21, 2025).

FinCEN issued an order granting an exemption from customer identification program requirements to allow banks to use alternative collection method to obtain customer TIN information before account opening (June 27, 2025).

FinCEN issued orders under the Fentanyl Sanctions Act and the FEND Off Fentanyl Act that identifies three Mexico-based financial institutions as being of primary money laundering concern (June 25, 2025).

FinCEN issued a finding and proposed rule under Section 311 of the USA PATRIOT Act that identifies Cambodia-based Huione Group as a financial institution of primary money laundering concern (May 1, 2025).

FinCEN issued alert on oil smuggling schemes on the U.S.-Mexico border associated with Mexican-based cartels (May 1, 2025).

FinCEN issued alert on bulk cash smuggling and repatriation by Mexican-based Transnational Criminal Organizations (March 31, 2025).

FinCEN issued an interim final rule that exempts U.S. companies and U.S. persons from the requirement to report beneficial ownership information under the Corporate Transparency Act (March 21, 2025).

Consistent with an earlier announcement by the U.S. Department of the Treasury suspending enforcement of the Corporate Transparency Act against U.S. citizens and domestic reporting companies, FinCEN issued an interim final rule that exempts U.S. companies and U.S. persons from the requirement to report beneficial ownership information under the Corporate Transparency Act, and sets a new deadline for reporting for foreign companies that meet the definition of "reporting company" and do not qualify for an exemption from reporting requirements (March 21, 2025).

New Administration Outlook: Helping you navigate post-election uncertainty in 2025 and beyond—insight and analysis from Davis Wright Tremaine attorneys.