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Guidance

FinCEN has extended for another two years a conditional exception to the strict operation of the "Travel Rule" (31 CFR 103.33(g)). The Travel Rule requires a financial institution to include certain information in transmittal orders relating to transmittals of funds of 3,000 or more. This…

Guidance

The Financial Crimes Enforcement Network has an obligation to ensure that data collected under the Bank Secrecy Act are properly collected, securely maintained and appropriately disseminated. Following the unauthorized and unlawful disclosures of certain Suspicious Activity Reports to the press…

Guidance

This serves notice that the Director of the Financial Crimes Enforcement Network (FinCEN) has granted a waiver from civil money penalties for violations of the Bank Secrecy Act, 31 U.S.C. 5314, and its implementing regulation, 31 C.F.R. Part 103.24, to persons who enter into settlement and…

Guidance
Question:

My money services business understands that Bank Secrecy Act regulations (31 C.F.R. Part 103) require, among other things, implementing a written anti-money laundering program and maintaining records of certain transactions. Because of the nature of my business, I would prefer to…

Guidance

The Financial Crimes Enforcement Network (FinCEN) receives numerous questions concerning compliance with the Bank Secrecy Act (BSA) recordkeeping requirement found in 31 C.F.R. §103.29. This section requires financial institutions to verify a customer’s identity and retain records of certain…

Guidance

This FinCEN interpretive guidance clarifies that reports filed with the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) of blocked transactions with Specially Designated Global Terrorists, Specially Designated Terrorists, Foreign Terrorist Organizations, Specially…

Case Examples

A multi-agency money laundering/marijuana trafficking investigation was initiated following the filing of a SAR by a bank in Tennessee. The SAR disclosed that an individual was depositing large amounts of U.S. currency into three bank accounts. The deposits ranged from $5,000 to $25,000 with the…

Case Examples

The Pennsylvania (Pa.) Office of Attorney General’s Asset Forfeiture and Money

Laundering Section conducted proactive targeting research on SARs that initiated a Pa. State Grand Jury Money Laundering investigation on two suspects.

FinCEN’s Gateway Program was utilized by the Pa.…

Case Examples

In 2005, a federal task force initiated a 2-year multi-agency investigation against an online pharmaceutical distribution network, resulting in indictments against 18 individuals. The investigation was based on information received from a cooperating witness, who alleged that a pharmaceutical…