Financial Crimes Enforcement Network

And as you mentioned, the United States moving away from domestic reporting.

FinCEN's August 2026 file and rule permanently removed Corporate Transparency Act for reporting requirements in the US.

So I'd say the current landscape is best described as a global UBO divide, where on one side, a country is moving away, and on the other, there are some countries in the EU which have moved in the opposite direction.

revised their anti-money laundering framework and transparency act where some information has to be collected stored centrally and is available through a different collection and access model.

could be broken up by the federal government.

Maybe we'll have FinCEN rules put back in place, that sort of thing, that'll turn Hollywood back into an open market that flourishes.

But, you know, I've been here for 10 years and I've seen it do nothing but shrink.

If you were granted a sit down with David Ellison, how would you approach the conversation?

In regulatory and legal developments, the UK Financial Conduct Authority has imposed restrictions on six Annex 1 lenders over anti-money laundering deficiencies.

while a coalition of 21 state attorneys general has sued FinCEN over its rollback of Corporate Transparency Act beneficial ownership reporting rules.

Finally, on cybercrime, Interpol's Operation Serengeti 3 has netted 1,462 arrests and recovered over $105 million across Africa.

The former UK minister has indicated state involvement in the Jaguar Land Rover cyber attack, and a Ukrainian ransomware affiliate has been sentenced to 70 months in federal prison.

Sentencing is scheduled for 8 February next year.

Now let's take a look at the one piece of other financial crime news this week.

And it's a story that's been building for a while, but a coalition of 21 state attorneys general has filed an action in the U.S. District Court for the District of Oregon, challenging a rule issued by the Treasury Department's Financial Crimes Enforcement Network, or FinCEN.

The complaint alleges that FinCEN violated the Corporate Transparency Act and the Administrative Procedure Act by exempting U.S. companies and individuals from beneficial ownership information reporting requirements designed to identify company ownership and assist law enforcement in detecting money laundering, tax fraud, and other financial crime.

Why haven't we had a real look into the financials here? You mean to tell me all of the financial transactions Epstein was moving through this bank were on the up and up? We already know that's not the case.

We've already seen the fines that these banks have got slapped with for their malfeasance, for not respecting the FinCEN process.

But none of these bankers, the men in charge, the women in charge, the people at the top, when do any of them get held accountable? Nobody goes to prison.

None of these people ever go to prison.

There is a lot, a lot of circumstantial evidence of money laundering here, folks.

Obviously, it's only... what we can see on the surface, right, and what any inside sources say.

But when you start talking about suspicious activity reports, Title 31, how they weren't filed, fines for Deutsche Bank for not following FinCEN database regulation, look, it all starts to add up.

Where there's smoke, there is usually fire.

When otherwise they would be up finding you can correct these in the normal course of business.

And you see a lot of those with BSA issues and FinCEN related issues because we have agreements with other agencies that these items will be a document or resolution.

NCUA has agreements.

Keep throwing we in there.

If you have a bank account outside US more than 10,000 US dollars anytime in the year.

then you have to report all your foreign accounts to FinCEN.

So that's annual requirement with the same deadline as your taxes.

And people might miss out, they might think, because obviously when you have a property, you might have an account, you might have money accumulating there.

Maine and 20 other states are suing the Trump administration to stop them from gutting the Corporate Transparency Act.

The CTA is an anti-money laundering law passed in 2021 that helps prosecutors prevent white collar crime by requiring corporations, including shell companies, to report all transactions to the U.S. Treasury Department's Financial Crimes Enforcement Network.

But last year, the Trump administration exempted virtually all businesses from the law's reporting requirements.

And in August, it issued a final rule making the exemptions permanent and agreed to a data purge.