All in BSA

On September 8, 2025, FinCEN reiisued a modified Geographic Targeting Order (GTO) to combat illicit cartel and other criminal activity, including money laundering, along the southwest border of the United States. FinCEN previously issued a notice of a GTO requiring certain money services businesses along the southwest border to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions.

On September 5, 2025, FinCEN issued guidance to encourage and promote appropriate, voluntary cross-border sharing of information between and among financial institutions, including appropriate foreign financial institutions. According to FinCEN, the Guidance aims to help combat the threats posed by money laundering, terrorist financing, and other illicit finance activity, including from drug trafficking organizations, foreign terrorist organizations, and fraudsters.

On August 19, 2025, FinCEN extended the effective dates for orders issued on June 25, 2025, prohibiting certain transmittal of funds involving three Mexico-based financial institutions. Covered financial institutions will now have until October 20, 2025, to implement the orders prohibiting certain transmittal of funds involving CIBanco S.A., Institución de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector).

On August 6, 2025, FinCEN published a Readout regarding its latest FinCEN Exchange held on July 15 where it convened Treasury components, law enforcement agencies, financial institutions, regulatory technology companies, and trade groups to share insights on driving innovation in the digital assets ecosystem while protecting consumers from emerging fraud and scam threats. The FinCEN Exchange event, titled “Advancing Digital Assets Innovation While Safeguarding Consumers Against Fraud and Scam Risks,” focused on industry trends, fraud prevention, law enforcement's role in combating financial crimes related to digital assets, and compliance best practices.