An AML Year in Review

Financial Services Regulations attorneys Peter Hardy, Andres Fernandez, Gabriel Caballero, Siana Danch and Daniel Noste co-authored an article for the American Bankers Association's Banking Journal tracking developments in anti-money laundering (AML) regulation and enforcement in the United States throughout 2025. As the authors explain, the Trump Administration prioritized combating transnational criminal organizations (TCOs) and cartels utilizing the Bank Secrecy Act (BSA) and AML rules, from designating some cartels as terrorist organizations to issuing new reporting requirements for money transmitters in the southwestern part of the country to preventing U.S. financial institutions from transacting with certain foreign financial institutions. The article goes on to outline how the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) addressed money laundering risks presented by cartels and TCOs and how it sought to execute the administration's agenda. The attorneys also review steps for U.S. financial institutions to take to maintain compliance with BSA/AML regulations and avoid unwanted attention from FinCEN, such as conducting customer risk assessments and monitoring transactions, training employees and supervisors on filing currency transactions reports (CTRs) and suspicious activity reports, and vetting correspondent bank account relationships with foreign banks.

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