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Clifford Chance

Clifford Chance


Impact of FinCEN Priorities Statement on FCPA/Anti-Bribery, Cryptocurrency, and Export Controls

July 30, 2021

The U.S. Department of Treasury's Financial Crimes Enforcement Network issued its national priorities in the Government's efforts to combat money laundering and terrorist financing. FinCEN has made statements about priorities in the past, although not pursuant to a statutory mandate. Although still broad, the new statutorily mandated priorities are more specific than those listed by FinCEN around five years ago. FinCEN used to note at the bottom of its enforcement-related press releases that its focus was "on compromised financial institutions and their employees; significant fraud; third-party money launderers; transnational organized crime and security threats; and cyber threats."

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