Regulatory & Enforcement

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Key Takeaways:

  1. The Russian Federation, Bolivia and the British Virgin Islands (“BVI”) have been added to the EU list of third countries deemed high risk for AML/CTF purposes.
  2. The EU has removed Burkina Faso, Mali, Mozambique, Nigeria, South Africa, and Tanzania from this list.
  3. The EU’s position redefines the risk landscape for entities with exposure to Russian, Bolivian, and BVI organisations or individuals, and consequently increases commercial pressure on EU/Russian relationships with extensive global sanctions already imposed due to the ongoing Russia/Ukraine conflict.
Continue Reading EU Amendments to List of High-Risk AML/CTF Countries

The UK’s Office of Financial Sanctions Implementation (OFSI) has launched a call for evidence concerning the “ownership and control” test within UK financial sanctions. The call for evidence, running until 11:59 p.m. on 13 April 2026, seeks stakeholder views on the challenges and implementation of the “control” limb, with particular focus on its hypothetical element.

Continue Reading UK Government Seeks Evidence on Ownership and Control in Financial Sanctions Regulations

On January 14, 2026, State Senator Zellnor Myrie proposed legislation in the New York State Senate that would amend New York law to make it a criminal offense to operate a virtual currency business in New York without the proper license. By introducing the possibility of criminal penalties, Senate Bill S. 8901, the Cryptocurrency Regulation Yields Protections, Trust, and Oversight Act (CRYPTO Act), would mark a significant regulatory shift in the state’s oversight of virtual currency businesses, given New York’s prominence in virtual currency regulation in the U.S.

Continue Reading Proposed NY Legislation May Mean Potential Criminal Charges for Unlicensed Crypto Firms

On December 19, 2025, New York Governor Kathy Hochul vetoed a bill that would have amended the New York LLC Transparency Act (“New York Act”) to include beneficial ownership information (“BOI”) reporting requirements for all non-U.S. and U.S. limited liability companies (“LLCs”) registered to do business in New York State (“New York”).

The Governor’s veto means that the New York Act willonly require disclosure of BOI only for non-U.S. LLCs registered to do in business in New York that do not otherwise qualify for any of the exemptions in the New York Act, and only with respect to non-U.S. beneficial owners.

Continue Reading Governor’s Veto Limits Scope of New York LLC Transparency Act to Foreign LLCs Registered in New York

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 there. The agency says this resulted in six FinCEN Notices of Investigation, “dozens” of referrals to the IRS, and 50 compliance outreach letters. An accompanying video from Treasury Secretary Scott Bessent suggests that the initiative is intended to “stop terrorist cartels, drug traffickers, and human smugglers” and to “root out potential cartel-related money laundering from the U.S. financial system.”

Continue Reading FinCEN Announces Enforcement Initiative for MSBs Along the Southwest Border

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.…

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…

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…

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