Kaitlin Cassel

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FinCEN Expands its Real Estate GTOs, Citing Value of Initial Orders

Consistent with the trend we noted previously, FinCEN has expanded its real-estate focused Geographic Targeting Orders (GTOs).  The new GTOs target real estate transactions beyond Manhattan and Miami to include six geographic areas:  all boroughs of New York City, and counties in or near Miami FL, Los Angeles CA, San Francisco CA, San Diego CA, … Continue Reading

FinCEN Reissues Final Rule Against FBME Bank

On March 25, 2016, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that it is reissuing a final rule against FBME Bank Ltd. (FBME).  Under Section 311 of the USA PATRIOT Act, FinCEN has authority to designate a foreign financial institution as a “primary money laundering concern” and promulgate a rule imposing “special measures” … Continue Reading

Smart Tools and Targeted Enforcement: FinCEN’s Increasing Use of Geographic Targeting Orders

The current leadership of the Financial Crimes Enforcement Network (FinCEN) aggressively has sought to close gaps in its anti-money laundering enforcement efforts.  We’ve blogged about some of FinCEN’s recent efforts (here and here) to broaden regulation and bring new types of enforcement actions.  Along similar lines is FinCEN’s increasing use of Geographic Targeting Orders (GTOs) … Continue Reading

FinCEN’s Expanding Enforcement in 2015

The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) was very active in the waning days of 2015.  And FinCEN’s message from this activity is clear – it is closing any gaps it finds in anti-money laundering (AML) enforcement, including for non-traditional financial institutions, not used to being the focus of regulation, but increasingly the choice … Continue Reading