Yesterday, FinCEN announced an ongoing enforcement initiative against more than 100 money services businesses (“MSBs”) operating along the Southwest U.S. border. FinCEN says that it reviewed over one million currency transaction reports (“CTRs”) and 87,000 suspicious activity reports (“SARs”) using new data processing techniques to identify potential Bank Secrecy Act (“BSA”) compliance concerns with MSBs
Regulatory & Enforcement
Paul Haskel and Paul Pollock Publish Article on MSOs in Bloomberg Law
By Paul B. Haskel & Paul J. Pollock on
The use of management service organizations (MSOs) in the law firm space is a new and expanding trend. While uncertainties whether MSOs comply with legal ethical rules remain, with only one decision from the Texas Commission on Professional Ethics touching on the issue so far, continued use of MSOs in law firm transactions is expected.…
UK Government Intends Third-Party Funding Regulatory Streamlining
The UK Ministry of Justice has announced an intention to remove English third-party litigation funding from the current requirements of the Damages-Based Agreements Regulations 2013 (“DBA Regulations”) and provide for a different regulatory framework. As we have discussed previously here and here, various forms of uncertainty remain for third parties who wish to fund…
New York LLC Transparency Act: Key Requirements and Deadlines
Posted in Financial Services, Regulatory & Enforcement
On January 1, 2026, the New York LLC Transparency Act is scheduled to take effect, introducing new disclosure requirements for limited liability companies in New York State.
The legislation will have significant implications for all LLCs formed or registered to do business in New York. Furthermore, a proposed amendment awaiting the Governor’s signature would broadly…
FinCEN and Banking Regulators Issue New FAQs on Suspicious Activity Reports
By Carlton Greene, Erik Woodhouse & Jackie Schaeffer on
Posted in Regulatory & Enforcement
Banks and other regulated financial institutions have been digesting a set of four frequently asked questions (“FAQs”) about suspicious activity reports (“SARs”) issued jointly on October 9, 2025 by FinCEN and federal banking regulators (the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration). According to remarks the same day from Treasury Secretary Scott Bessent, the FAQs are intended to reduce the compliance burdens associated with filing SARs without diminishing the benefit of SAR reporting to law enforcement.Continue Reading FinCEN and Banking Regulators Issue New FAQs on Suspicious Activity Reports