Mid-Year 2025: Key AML Enforcement and Rulemaking Issues That U.S. Institutions Are Working On

Mid-Year 2025: Key AML Enforcement and Rulemaking Issues That U.S. Institutions Are Working On

U.S. financial institutions are focusing on anti-money laundering enforcement and upcoming rulemaking in mid-2025, aiming to strengthen compliance and mitigate regulatory risks

In Washington, D.C., August 2025.   A lot changed in 2025 about how the United States executes its anti-money-laundering (AML) regulations.  This was because FinCEN was severe about following the rules and adopting new ones under the Bank Secrecy Act (BSA).

  The Gibson Dunn Mid-Year AML Update (August 4, 2025) and DLA Piper's 2025 Financial Regulatory Outlook both show a clear trend: sanctions, counter-narcotics enforcement, and AML compliance are all coming together. The regulatory net is getting bigger and bigger, reaching far beyond traditional banks.

  1. More Sanctions—AML Convergence Focus Areas:

  FinCEN's use of the FEND Off Fentanyl Act to blacklist Mexican banks has created a new mechanism to enforce the law that includes drug-trade financing, sanctions, and AML standards.

  Trade-based money laundering (TBML): U.S. law enforcement is keeping an eye on peculiar trade patterns, goods that could be used for more than one thing, and invoices that change across borders.

  Information about Effects:

  In the first half of 2025, FinCEN had 47% more Suspicious Activity Reports (SARs) that talked about payments for fentanyl or chemicals that are used to make it.

  The DOJ and OFAC looked into 22 examples where networks that laundered money broke the law.  This is nearly two times more than in 2024, according to Gibson Dunn data.

  Keep this in mind:

  Regulators now expect AML and sanctions controls to work together, with all compliance operations using the same screening, alert escalation, and narrative.

  2. Expanding the BSA to include more than just banks

  The Bank Secrecy Act's definition of "financial institution" now encompasses non-traditional sectors that were believed to be low-risk at first.

  Sector: Regulatory Action; Source   The BSA is keeping a check on galleries and auction houses because of the Art Market Integrity Act (S. 2400).  Gibson Dunn and Congress.gov   Investment Advisors and Private Funds  FinCEN's proposed rule from March 2025 stipulates that RIAs and private equity firms must have anti-money laundering (AML) procedures and file suspicious activity reports (SARs).  DLA   FinCEN.gov and Piper Alert Property  The proposed change to the Beneficial Ownership Transparency Act includes new rules for identifying consumers in transactions involving valuable property.  Gibson Dunn   Note to Client: August 2025   Why It Matters:

  People utilise these loopholes to avoid paying taxes, avoid penalties, and wash expensive products. These additions are aimed to close them.   Non-bank businesses, especially art dealers, consultancies, and auction sites, now need to build up compliance systems like banks do. These systems include AML officers, SAR procedures, and checks on who owns what.

  3. Due diligence across borders becomes more important

  The notifications in the middle of the year show that regulators want more from cross-border risk assessment, notably in these areas:

  Mexico and China have separate lanes for shell importers and precursor chemicals.

  People in Hong Kong, Dubai, and Singapore act as middlemen for multilayer transactions.

  Remittance and cryptocurrency exchanges linking the U.S. and Latin America

  FinCEN Guidance (May 2025):

  Institutions must keep records of geo-risk ratings for clients who live in high-risk locations.

  It should be easy to see how cross-border counterparties and suspicious trade flows are linked in SAR tales.

  Regulators like monitoring that is based on data, such AI-based pattern recognition, better than systems that are based on rules.

  "Cross-border activity is no longer just a footnote in AML reviews; it's the main focus."   Institutions should be able to accurately map international exposure the same way they do sanctions screening.   — Gibson Dunn   AML Report for the Middle of 2025

  4. Data Highlights on Enforcement Momentum   Metric H1 2024 H1 2025 Δ YoY Civil Penalties from FinCEN (USD)  $590 million  $1.07 billion, an increase of 81%   Charges from the DOJ for AML and sanctions  17 cases, 31 cases, and 82% more   Filed SARs (All Sectors)  1.2 million 1.8 million +50%   The average fine for a business is $4.8 million.  $7.2 million, which is 50% higher

  (Source: Gibson Dunn, DLA Piper Regulatory Monitor 2025)

  ⚙️ 5. What Compliance Teams Should Work on in the Last Half of 2025

  "What to Do Now"   Boxout for Compliance Leaders

  1️⃣ Make it tougher to identify connections between China and Mexico   Find counterparties or suppliers who work in high-risk regions and apply trade-based anti-money laundering filters to payment systems.

  2. Look over the rules for beneficial ownership   Get ready for the launch of FinCEN's Beneficial Ownership Information (BOI) system, which is expected to go into effect by December 2025.

  3. Make SAR Narratives Better   Include information on the cryptocurrency, the location, and the structure of the transaction.   Regulators want more precise information today, not just nebulous language like "suspicious pattern."

  4. Put the AML, sanctions, and fraud departments together   Make sure that compliance teams can share data and keep an eye on things to avoid having to do separate monitoring.

  5. Check out third-party vendors   You should do your own research on AML software and models for keeping an eye on cross-border transactions.

  Editorial Angle for Financial-Journal.xyz

  This article makes Financial-Journal.xyz a great site for CEOs, general counsels, and risk officers to learn about rules and how to obey them.

  Headlines that could be used for syndication:

  "Following the Rules in a World Where FinCEN Can Reach Anyone: The 2025 AML Cross-Border Crackdown"

  "Art, Assets, and Algorithms: How FinCEN's 2025 Rules Change What It Means to Be a 'Financial Institution'"