Integritas³

Regulatory Insight from Integritas³ FinCEN Clarifies Suspicious Activity Reporting (SAR) Requirements On October 9, 2025, the Financial Crimes Enforcement Network (FinCEN)—together with the Federal Reserve, FDIC, NCUA, and OCC—released updated FAQs on Suspicious Activity Reporting (SAR) obligations under the Bank Secrecy Act (BSA). The guidance aims to help financial institutions streamline compliance efforts while maintaining effective anti-money laundering and countering the financing of terrorism (AML/CFT) programs that provide the greatest value to law enforcement and regulators. Key Updates: 1. Structuring: Transactions near the $10,000 CTR threshold do not automatically require a SAR. A report is necessary only when the institution knows, suspects, or has reason to suspect an attempt to evade reporting. 2. Continuing Activity Reviews: Financial institutions are not required to conduct separate manual reviews of customer accounts after filing a SAR. Monitoring should follow each institution’s risk-based policies and controls. 3. Filing Timeline: FinCEN’s historical 90-day “rule of thumb” for continuing activity filings is guidance, not a mandate. Institutions may file subsequent SARs as appropriate within standard timelines. 4. No SAR Documentation Requirement: Institutions are not required to document decisions not to file a SAR. However, brief internal notes may be prudent in complex investigations. These clarifications do not change existing legal or regulatory requirements. Instead, they underscore FinCEN’s intent to promote risk-focused, resource-efficient compliance and stronger alignment with law enforcement priorities. Read the full release from FinCEN: https://lnkd.in/ezYUhADa #FinCEN #IRS

Traditional “placement, layering, and integration” no longer capture how criminals move and disguise illicit funds. In this ACFCS article, authored by our partner Kenneth Hines, explores how money laundering has evolved into a multi-directional and adaptive process, reflecting today’s digital and global realities. #Fraud #ACFCS #AML https://lnkd.in/gya8urQ7

The new FinCEN Advisory FIN-2025-A003 is a must-read. Chinese Money Laundering Networks (CMLNs) show how modern laundering bypasses the classic “three stages” and instead functions as a global settlement system. Capital-control arbitrage, mirror swaps, and trade-based laundering illustrate why we need to rethink typologies and train investigators, regulators, and advisors on these modern elements. #FinCEN #MoneyLaundering #AML #FinancialCrime #Compliance

FinCEN Advisory FIN-2025-A003: The Modern Elements of Money Laundering. The latest FinCEN Advisory (FIN-2025-A003) highlights Chinese Money Laundering Networks (CMLNs) as professionalized, decentralized systems that launder Mexican cartel drug proceeds. These networks demonstrate nearly all of the modern elements simultaneously, underscoring the limitations of the classic model. Acquisition & Access: Cartel-generated USD becomes the raw illicit value. Rather than smuggling cash back to Mexico, CMLNs acquire it in the U.S. at a discount. Initial Integration (Front-loading): CMLNs immediately match cartel dollars with Chinese nationals seeking to circumvent PRC capital controls. This arbitrage turns illicit drug money into legitimate-seeming RMB at the outset. Dispersal & Conversion: Value is moved through mirror transactions (USD→MXN→RMB) without physical cross-border transfer. Additional conversion occurs via luxury goods, “daigou” networks, real estate escrow, or even cryptocurrency. Recycling & Legitimation: Cartel proceeds become indistinguishable from Chinese clients’ legitimate overseas investments, re-entering global markets under a veneer of lawful commerce. Preservation & Masking: Layered corporate entities, third-party “money mule” accounts, and real estate holdings safeguard value and obscure ultimate beneficial ownership. This typology illustrates how capital-control arbitrage and professional networks drive laundering today—not sequential layering. Mirror swaps, underground banking, and trade-based laundering act less like stages and more like interchangeable elements of a global settlement system. https://lnkd.in/ggRicQKH #AML #IRS #finCEN Integritas³

This afternoon at the 2025 Summer Tax Summit, the panel on NIL (Name, Image & Likeness) in College Sports tackled the fast-changing tax and legal landscape for student-athletes, collectives, and universities. The discussion examined not only compliance and planning opportunities but also the impact of recent case law—including the House v. NCAA settlement and ongoing litigation over antitrust and athlete classification—as well as IRS guidance (AM 2023-004) addressing income recognition, entity structuring, and reporting obligations. These developments highlight both the opportunities NIL creates and the pitfalls if compliance is overlooked. Panelists: ·      Kevin Hanff, Partner Integritas³ (Pensacola, FL) – former IRS-CI Assistant Special Agent. · Thad Madden, EA (Philadelphia, PA) – 38-year IRS veteran, specializing in NIL compliance issues. · Mark Milton, Esq., Managing Attorney, Milton Law Group (St. Louis, MO) – advising student-athletes on tax obligations and wealth-building strategies. ·      Aaron L. Pawlitz, Esq., Partner, Lewis Rice LLC (St. Louis, MO) – advising NIL collectives and athletes on structuring and compliance issues. A timely and insightful conversation on where college sports, tax law, and compliance intersect. hashtag #IRS #TaxSummit2025 #NIL #CollegeSports #TaxCompliance

This morning at the 2025 Summer Tax Summit we witnessed history with the “Mount Rushmore of CI Chiefs” panel. For the first time, the current and former Chiefs of IRS Criminal Investigation came together to discuss how CI leadership works with government, law enforcement, and private sector stakeholders to shape and enforce our nation’s criminal tax priorities. Panelists: ·       Guy Ficco, Chief, Internal Revenue Service – Criminal Investigation (Washington, DC) ·       Don Fort, Director of Investigations, Kostelanetz LLP (Washington, DC) ·       Jim Lee, Global Head of Capacity Building, Chainalysis (Washington, DC) ·       Victor Song S.O. Song, Partner, Integritas³ (Orange County, CA) This 50-minute session offered an extraordinary look at the evolution of IRS-CI’s mission, from uncovering complex tax fraud and financial crimes to building partnerships that strengthen enforcement globally. The panelists shared their decades of leadership and insights on what it means to guide the premier law enforcement agency in tax administration. #TaxSummit2025 #IRS #CriminalInvestigation #TaxEnforcement #Leadership

Join Us at the 62nd Annual Hawaii Tax Institute We’re excited to announce that our Partners, Victor Song and Kenneth Hines, will be presenting at the 62nd Annual Hawaii Tax Institute, taking place November 2–6, 2025, in Honolulu. They will share critical insights on: ·      Client Wealth Scams and Ethical Considerations: What Wealth Transfer Advisors Need to Know ·      Elder Financial Exploitation: Tools to Identify and Prevent Fraudster Schemes Joining them on the panel are two distinguished leaders: Tara Sullivan, Director of Field Operations – West, IRS Criminal Investigation The Honorable Hon. Lee R. Bogdanoff (Ret.) Why should I attend? The Hawaii Tax Institute is more than a conference—it’s one of the nation’s premier gatherings for tax, wealth, and estate planning professionals. Attendees gain: ·      Expert perspectives on emerging fraud risks and ethical challenges. ·      Practical tools to better protect clients and strengthen advisory practices. ·      An unmatched opportunity to connect with leaders across tax, law, and wealth management—all in the spirit of aloha. We look forward to connecting with you in Honolulu this November! #HawaiiTaxInstitute #TaxLaw #WealthManagement #ElderFinancialExploitation #Ethics #ForensicAccounting https://lnkd.in/gaV3g2p3

A New Chapter in Native Hawaiian Leadership Begins! Integritas3 is happy to share in this good news and celebrate this meaningful investment in the next generation of Native Hawaiian leadership. We applaud the Foundation and Hawai‘i’s Congressional Delegation for making this vision a reality. The Abigail Kawānanakoa Foundation proudly launched its inaugural program—the Prince Jonah Kūhiō Kalanianaʻole Fellowship—at a special ceremony at Mauna ‘Ala. This groundbreaking initiative places five outstanding young leaders from Hawaiʻi in yearlong fellowships with Hawai‘i’s Congressional Delegation in Washington, D.C. and at home in Hawai‘i. Rooted in the legacy of Princess Abigail Kinoiki Kekaulike Kawānanakoa, the fellowship honors her lifelong commitment to preserving Native Hawaiian identity through culture, language, and fearless advocacy. As Judge Patrick K.S.L. Yim (ret.), Foundation Board Chair, shared: “Princess Kawānanakoa believed Hawaiians should never be silent when our future is on the line — this fellowship honors that belief.” The 2025–2026 Kūhiō Fellows are: Kala‘i Anderson – Maui, Hawaiʻi (Rep. Jill Tokuda) Kenna Higa – Honolulu, Hawaiʻi (Rep. Ed Case) Brandee Markwith – Honolulu, Hawaiʻi (Sen. Brian Schatz) Neill Natori – Honolulu, Hawaiʻi (Sen. Mazie Hirono) Josh Worth – Maui, Hawaiʻi (Sen. Brian Schatz) These remarkable individuals were selected for their academic excellence, cultural grounding, and commitment to service. As Foundation member James Wright emphasized: “We’re planting seeds of leadership that will grow into strong, culturally rooted voices in government… this is about building a future where Hawaiians lead with confidence, kuleana, and aloha.” Applications for the 2026–2027 cohort will open later this year. Learn more: kawananakoafoundation.org #KuhioFellows #HawaiianLeadership #NativeHawaiianFuture #AbigailKawānanakoaFoundation #CivicEngagement #AlohaInAction #HawaiianCulture #PublicService #LahuiStrong #KuleanaToLead #Integritas3

Excited to share that our partner Victor Song will be joining a truly historic panel at the 2025 Summer Tax Summit in St. Louis — alongside current and former Chiefs of IRS Criminal Investigation Guy Ficco, Don Fort, and Jim Lee. For the first time ever, this Mount Rushmore of IRS-CI leadership will be on one stage discussing all things #CriminalTax — investigations, enforcement trends, and where things are headed next. Missouri Athletic Club | St. Louis August 25–26, 2025 This is more than just CLE/CPE — it’s a rare opportunity to gain insight from those who helped shape the government’s tax enforcement priorities and policies. 🔗 Register here: https://lnkd.in/euK5knJt #CriminalTax #TaxControversy #WhiteCollar #IRS #TaxEnforcement #StL #CPE #CLE #FederalBarAssociation #VictorSong #Integritas3 #Networking

Great conference and great lineup! Partners Kevin Hanff and Victor Song will be speaking on two very interesting panels. Come and join us!