On March 31, 2025, FinCEN issued an Alert on bulk cash smuggling and repatriation by Mexico-based Transnational Criminal Organizations (TCOs). The Treasury, alongside FinCEN, is urging financial institutions to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by these Mexico-based criminal organizations.

On March 24, 2025, FinCEN issued a set of Frequently Asked Questions for the Geographic Targeting Order involving certain money services businesses in California and Texas on the Southwest Border. This is in relation to the March 11 GTO requiring all money services businesses located in 30 ZIP Codes across California and Texas to file additional Currency Transaction Reports (CTRs) with FinCEN for transactions above $200 but not more than $10,000.

On March 21, 2025, FinCEN issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption must report their BOI to FinCEN under new deadlines.

On March 11, 2025, FinCEN issued a notice of a Geographic Targeting Order requiring certain money services businesses along the southwest border of the United States to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions. The order will take effect starting April 14, 2025 and ends on September 9, 2025.

On 2/27/25, FinCEN announced that it will not impose fines, penalties, or any other enforcement actions against companies that fail to file or update beneficial ownership information (BOI) reports under the Corporate Transparency Act by the current deadlines. In a news release, FinCEN stated that “no fines or penalties will be issued, and no enforcement actions will be taken, until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.”

On 2/26/25, FinCEN issued an advisory to remind financial institutions to remain vigilant regarding suspicious activity that may be indicative of relationship investment scams. This alert was issued in support of the multiagency #DatingOrDefrauding Campaign launched by the Commodity Futures Trading Commission to alert the public to relationship investment scams targeting Americans through wrong-numbered texts, dating apps, and social media. The advisory states that losses from romance and confidence scams reported to the Federal Bureau of Investigation exceeded $650 million in 2023.

On February 26, 2025, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT/CPF deficiencies. In this latest update, the FATF added Laos and Nepal to the list of Jurisdictions Under Increased Monitoring and removed the Philippines. The list of High-Risk Jurisdictions Subject to a Call for Action remains unchanged, with Iran, North Korea (DPRK), and Burma still subject to FATF’s highest level of scrutiny. Specifically, FATF continues to call for countermeasures against Iran and DPRK, while Burma remains subject to enhanced due diligence.

On 2/21/25, the US Department of Treasury reported that the Financial Action Task Force (FATF) concluded a plenary in Paris, where Treasury representatives participated in discussions on proliferation and terrorist financing risks, financial inclusion, and payment standards, leading to draft updates for public consultation. The Treasury also reported that FATF launched a public consultation on sanctions evasion schemes and endorsed changes to its recommendations to reinforce a risk-based approach to combating illicit finance, including ensuring preventive or mitigation measures are commensurate with the risks identified.

On 2/20/25, OFAC launched a new “File Finder” application for use on its website. The application is browser-based and allows “users to search through and efficiently navigate all of OFAC’s website content,” according to a release by OFAC. OFAC explains that the new application “searches all static content on OFAC's website (PDF documents, word documents, etc.) by document title, document type, and the contents of each document. Searchable content typically includes general licensees, federal register notices, executive orders (and other legal documents), press charts, advisories, specific guidance, as well as many other records.”

On February 19, 2025, FinCEN updated the Alert on its Beneficial Ownership Reporting page stating that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect as a result of the decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al. However, FinCEN is generally extending the deadline by 30 calendar days from February 19, 2025, for most companies considering that reporting companies may need additional time to comply with their BOI reporting obligations.