FinCEN AML/BSA Enforcement

Current understanding

To be populated as evidence accumulates.

Evidence log

• 2026-09-01 — Proposal of Special Measure Regarding Banque Misr UAE as a Financial Institution Operating Outside of the United States of Primary Money Laundering Concern: cross-connection with fincen-banque-misr-uae-section-311: Section 311 special-measure proposals are part of FinCEN’s broader AML/BSA enforcement toolkit against foreign institutions. (novelty: 3)
• 2026-09-04 — Geographic Targeting Order Imposing Recordkeeping and Reporting Requirements on Certain Money Services Businesses Along the Southwest Border: cross-connection with fincen-geographic-targeting-orders: Southwest border GTO is a BSA/AML enforcement tool used by FinCEN in parallel with its broader AML enforcement program. (novelty: 2)
• 2026-08-14 — Beneficial Ownership Information Reporting Requirement Revision: cross-connection with beneficial-ownership-information-reporting: Reducing BOI reporting scope shifts what beneficial-ownership data FinCEN has available for AML/BSA enforcement and investigative use. (novelty: 4)
• 2025-03-11 — SHIELD Against CCP Act: cross-connection with shield-against-ccp-act: Illicit finance stream of the DHS CCP working group would overlap with FinCEN AML/BSA priorities on China-linked money laundering and trade-based financial crime. (novelty: 2)
• 2026-07-13 — Novedades Y Servicios, Inc. v. Financial Crimes Enforcement Network: Ninth Circuit issued an opinion in Novedades Y Servicios, Inc. v. FinCEN on July 13, 2026; caption and date are known but the abstract does not disclose the holding or doctrinal impact on BSA/AML enforcement. (novelty: 2)

Open questions

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