On August 21, 2019, FinCEN issued an advisory (the “Advisory”) alerting financial institutions to various financial schemes and mechanisms employed by fentanyl and synthetic opioid traffickers to facilitate the illegal fentanyl trade and launder its proceeds.

As defined by the Centers for Disease Control and Prevention (“CDC”), “fentanyl is a synthetic (man-made) opioid 50 times

In this podcast, we review recent developments dealing with the provision of financial services to the cannabis industry, including state approaches to banking services, the status of hemp legalization, the interplay between federal and state cannabis law, FinCEN guidance on BSA expectations, the status of federal regulatory and enforcement activity, and the status and prospects

The CFPB’s Office of Financial Protection for Older Americans has issued a new report on combating elder abuse. Titled “Suspicious Activity Reports on Elder Financial Exploitation: Issues and Trends,” the report draws on a non-public data derived from Suspicious Activity Reports (SARs) filed with federal regulators from 2013 to 2017.

This data became

The Federal Banking Agencies (“FBAs”) — collectively the Office of the Comptroller of the Currency (“OCC”); the Board of Governors of the Federal Reserve System (“Federal Reserve”); the Federal Deposit Insurance Corporation (“FDIC”); and the National Credit Union Administration (“NCUA”) — just issued with the concurrence of FinCEN an Order granting an exemption from the

As we reported in an earlier posting, it has taken considerable effort to locate the memoranda of understanding (MOUs) that the CFPB has put in place with various other federal agencies. More of those MOUs recently surfaced through, we believe, a Freedom of Information Act (FOIA) request. One of the newly uncovered MOUs is