On December 22, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a multifaceted data-driven operation to address potential money laundering, focused on more than 100 U.S. money services businesses (MSBs) operating along the southwest border. MSBs are non-bank financial institutions that provide certain financial services, including money transmission, check cashing,…

The Senate has introduced the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act, or the STREAMLINE Act, an initiative led by Senate Banking Committee Chairman Tim Scott and Senator John Kennedy, with support from several Republican co-sponsors.

For the first time in over five decades, the bill would modernize…

The Financial Crimes Enforcement Network (“FinCEN”) has recently taken two steps in furtherance of the Trump Administration’s deregulatory agenda.  In late September, FinCEN posted a notice to the Federal Register soliciting comments on a proposed “Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Compliance” to be completed by non-bank…

After years of waiting, the U.S. Department of Defense (DoD) posted to the Federal Register for public inspection on September 9, 2025, a final rule implementing the Cybersecurity Maturity Model Certification 2.0 (CMMC 2.0) standards into the Defense Federal Acquisition Regulation Supplement (DFARS) (the Final Rule), which was formally published a day later on September…

On May 12, 2025, the United States Department of Justice’s (“DOJ”) Criminal Division released a major policy memorandum outlining its enforcement priorities for the upcoming year. Unsurprisingly, the number one priority for the Division was investigating and prosecuting white-collar crimes related to waste, fraud, and abuse—and particularly healthcare fraud. This emphasis on prosecuting healthcare fraud…

On May 22, 2025, the Supreme Court published its opinion in Kousisis v. United States, No. 23-909, 605 U.S. __ (2025), holding that one who induces a victim to enter into a transaction under materially false pretenses may be convicted of federal fraud even without the intent to cause the victim economic loss. In…

On May 6, 2025, the U.S. Food and Drug Administration (FDA) announced a plan to expand its use of unannounced inspections of foreign manufacturing facilities that produce foods, essential medicines and other medical products intended for American consumers and patients. The FDA stated that this new inspection strategy will ensure that foreign manufacturers receive the…