On 11/9/21, the Financial Crimes Enforcement Network (FinCEN) announced that they convened a virtual FinCEN Exchange with members of the financial industry and law enforcement to discuss FinCEN’s analysis of suspicious activity reporting (SAR) with a transactional nexus to Alabama, Florida, Georgia, Mississippi, and South Carolina. Topics of discussion in the exchange included an analysis of certain Bank Secrecy Act (BSA) filing statistics for SARs and an analysis of SAR filings related to recent FinCEN advisories.

On 11/8/21, FinCEN released an update to its 2020 advisory on ransomware and the use of the financial system to facilitate ransom payments. This release was done in connection with a set of actions announced by the Department of the Treasury which focused on disrupting criminal ransomware actors.

On 10/29/21, the Financial Crimes Enforcement Network (FinCEN) announced the renewal of its longstanding Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. The purchase amount threshold remains $300,000 for each covered metropolitan area.

On 10/26/21, FinCEN issued a press release to inform U.S. financial institutions that the Financial Action Task Force (FATF), an intergovernmental body that establishes international standards to combat money laundering, counter the financing of terrorism, and combat weapons of mass destruction proliferation financing (AML/CFT/CPF), has issued public statements updating its lists of jurisdictions with strategic AML/CFT/CPF deficiencies following its plenary meeting this month. U.S. financial institutions should consider the FATF’s stance toward these jurisdictions when reviewing their obligations and risk-based policies, procedures, and practices.

On 10/19/21, FinCEN announced that it had granted limited exceptive relief (FIN-2021-R001) to casinos from certain customer identity verification requirements in the context of online gaming. Specifically, the relief allows a casino to utilize suitable non-documentary methods to verify the identity of online customers, though the suitability or non-suitability of any particular method must be evaluated based on risk.

On 10/15/21, FinCEN issued a financial trend analysis on ransomware trends in Bank Secrecy Act reporting filed between January 2021 and June 2021. This report, which was required by the Anti-Money Laundering Act of 2020, focuses on pattern and trend information pertaining to ransomware, in line with FinCEN’s issuance of government-wide priorities for anti-money laundering and countering the financing of terrorism policy.

On 10/15/2021, the Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a new industry-specific brochure, “Sanctions Compliance Guidance for the Virtual Currency Industry.” In their release, the Treasury explained that this new resource is designed to help members of the virtual currency industry navigate and comply with OFAC sanctions.

On 9/23/21, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a range of questions related to the implementation of amendments to the Bank Secrecy Act (BSA) regarding the trade in antiquities. This ANPRM is the first in a series of regulatory actions that FinCEN will undertake to implement Section 6110 of the Anti-Money Laundering Act of 2020 (AML Act), which became law on January 1, 2021.

On 9/16/21, the Financial Crimes Enforcement Network (FinCEN) issued a notice (FIN-2021-NTC3) to call attention to an increase in online child sexual exploitation (OCSE). The Notice provides financial institutions with specific suspicious activity report (SAR) filing instructions, and highlights some financial trends related to OCSE.

FinCEN has updated its “SAR Filings by Industry” webpage to include data from 2020. In addition to this webpage, FinCEN has an interactive map and and Interactive SAR Stats which allow BSA professionals to analyze what types of suspicious activity are being reported in their areas. As this data allows specific sorting of the data, BSA professionals are able to sort by many different fields including primary regulator, county,