Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
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In this Compliance Clip (video), Adam explores a challenging scenario involving Suspicious Activity Report (SAR) obligations when the subject of the report is a member of the board itself. Through a real-world example, Adam highlights the tension between regulatory reporting requirements and strict confidentiality rules. Adam also points toward key guidance on how institutions should navigate this sensitive situation without breaching compliance expectations.
Our Regulation E Bootcamp is currently on sale in our store. Our Regulation E Bootcamp is designed to review the requirements of the Electronic Fund Transfer Act (EFTA), as implemented by Regulation E, including a deep dive into the liability and error resolution rules. The goal of this program is to cover the main elements of Regulation E that would apply to your organization while spending extra time on the areas that have the greatest risk for non-compliance. You can register for this program at www.compliancecohort.com/regulation-e-bootcamp.
On April 15, 2026, FinCEN published a Fact Sheet detailing that FinCEN’s Rapid Response Program (RRP) has facilitated the interdiction of $1.8 billion and the recovery of over $1 billion in stolen proceeds on behalf of 5,790 U.S. victims. RRP is a partnership between FinCEN, U.S. law enforcement, and foreign partners working together to help victims and their financial institutions recover stolen funds sent abroad as the result of cyber-enabled fraud.
On April 10, 2025, the FDIC rescinded FIL-32-2023 titled FDIC Clarifying Supervisory Approach Regarding Supervisory Guidance on Multiple Re-Presentment NSF Fees, describing the FDIC’s supervisory approach relating to supervised institutions assessing multiple non-sufficient funds (NSF) fees arising from the re-presentment of the same unpaid transaction.
On April 8, 2026, FinCEN and the OFAC issued a joint proposed rule to implement provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) in countering illicit finance. The GENIUS Act directs the Treasury to issue regulations that would treat permitted payment stablecoin issuers (PPSIs) as financial institutions for purposes of the BSA and impose anti-money laundering obligations on PPSIs.
On April 7, 2026, FinCEN issued a proposed rule intended to fundamentally reform financial institutions’ anti-money laundering and countering the financing of terrorism (AML/CFT) programs under the Bank Secrecy Act (BSA). According to FinCEN, the proposed rule would promote risk-based, reasonably designed programs and greater consistency in how banks are evaluated for effectiveness.
Get ahead of your SAR training with our “early bird“ offer—save $100 for a limited time. Our SAR Mastery program is a comprehensive, full-day training program. In approximately seven hours, you’ll get a practical, step-by-step walkthrough of the entire SAR process—from spotting suspicious activity to completing the form with confidence. Go beyond the basics with in-depth guidance on filing instructions, common pitfalls, crafting clear narratives, and applying key FinCEN guidance. You’ll also learn best practices for continuing SAR filings and get actionable tips to strengthen your program and enhance report effectiveness. Register now to take advantage of our early bird offer. To enroll, go to: www.compliancecohort.com/sar-mastery.
In this Compliance Clip (video), Adam discusses how financial institutions can approach BSA training for their board of directors in a way that aligns with examiner expectations while remaining practical and effective. Adam highlights key considerations around balancing foundational knowledge with ongoing updates, as well as tailoring content to a board-level audience. A transcript of this video is now available.
On April 7, 2026, the FDIC, the OCC, and the NCUA jointly issued a proposed rule to amend the respective requirements for their supervised institutions to establish and maintain effective risk-based anti-money laundering and countering the financing of terrorism (AML/CFT) programs designed to identify, assess, and mitigate risks of illicit finance. The amendments are intended to align each agency’s AML/CFT rules with changes concurrently proposed by FinCEN.
On April 7, 2026, the OCC and the FDIC jointly issued a final rule that codifies the elimination of reputation risk from their supervisory programs. The agencies believe that banking regulators’ use of the concept of reputation risk as a basis for supervisory criticisms increases subjectivity in banking supervision without adding material value from a safety and soundness perspective.
