The Anti-Money Laundering Quarterly

Designed for busy in-house counsel and compliance professionals, this newsletter summarizes key domestic and international anti-money laundering (AML) regulatory and enforcement developments from the past few months, with links to primary sources.

The most notable AML developments during the first quarter of 2026 included several actions signaling that targeted AML enforcement coupled with decreased regulatory burden remains a priority for the administration:

FinCEN Announces Relief to Streamline Customer Due Diligence Requirements: On February 13, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting relief to financial institutions from customer due diligence requirements. Under FinCEN’s 2016 Customer Due Diligence Rule, a covered financial institution must verify and identify beneficial owners of legal entity customers at each new account opening. Under the exemption order, a covered financial institution is required to identify and verify the beneficial owners of a legal entity customer in only the following circumstances: (1) when a legal entity customer first opens an account with the institution; (2) when the institution has knowledge of facts that reasonably call into question the reliability of previously obtained beneficial ownership information; and (3) as otherwise required based on the institution’s risk-based procedures for ongoing customer due diligence. The stated purpose of the exemption is to reduce the burden of compliance consistent with the January 31, 2025 Executive Order (E.O.) 14192, Unleashing Prosperity Through Deregulation.

FinCEN Issues Expanded Southwest Border Geographic Targeting Order: On March 10, 2026, FinCEN issued an expanded geographic targeting order (GTO) subjecting money services businesses (MSBs), located in certain counties in New Mexico and Arizona, to enhanced reporting requirements. MSBs provide financial services outside of a formal bank, and the GTO requires them to file with FinCEN Currency Transaction Reports for cash transactions between $1,000 and $10,000, as a means to combat drug trafficking.

FinCEN Now Accepting Whistleblower Tips on Fraud, Money Laundering, and Sanctions Violations: On February 13, 2026, FinCEN launched a dedicated website to confidentially accept whistleblower tips related to fraud, money laundering, and sanctions violations. The announcement specifically noted that the portal accepts tips related to the Bank Secrecy Act (BSA) and that whistleblowers may be eligible for awards if a tip leads to enforcement action.

There were also several significant enforcement actions involving systemic AML programmatic failures across jurisdictions:

Possible New Section 311 Designation for Swiss Bank: On February 26, 2026, FinCEN issued a notice of proposed rulemaking to designate Swiss MBaer Merchant Bank AG as a financial institution of primary money laundering concern, and to impose certain special measures that would, if implemented, restrict MBaer’s access to the U.S. financial system. Approximately three weeks earlier, on February 6, 2026, the Swiss Financial Market Supervisory Authority (FINMA) had revoked the bank’s license and ordered its liquidation. Public comments to the proposed rule closed on April 1, 2026, and it has not yet been finalized.

Saxo Bank Fined $50 million by Danish Authorities: On January 23, 2026, the Danish Financial Supervisory Authority (DFSA) announced an administrative fine of approximately DKK 313 million (approximately $50 million) against Saxo Bank for violating Denmark’s Anti-Money Laundering Act. According to the DFSA, between January 2021 and May 2023, Saxo Bank failed to collect information about the nature and purpose of certain customer relationships and to meet the requirements for ongoing monitoring of clients for whom Saxo Bank makes its trading platform available (known as “White Label Clients”).

The first quarter of 2026 also brought additional movement on the policy and regulatory front, most notably:

FinCEN’s Residential Real Estate Rule Vacated: On March 19, 2026, a federal judge in the Eastern District of Texas issued an order vacating FinCEN’s Rule implementing reporting requirements for parties involved in real estate closings to report the details of any non-financed transfer of residential real property involving an entity or trust to FinCEN. Flowers Title Companies, LLC successfully challenged the rule under the Administrative Procedure Act (APA), claiming that it exceeded FinCEN’s statutory authority under the BSA. FinCEN’s primary argument was that it derived its authority for the rule from 31 U.S.C. § 5318(g)(1), which authorizes FinCEN to require financial institutions to report “any suspicious transaction relevant to a possible violation of law or regulation.” The court rejected FinCEN’s position that all non-financed residential real estate transfers to entities or trusts are categorically suspicious. The court vacated the rule in full.