All in BSA

On March 6, 2026, FinCEN assessed an $80,000,000 civil money penalty against Canaccord Genuity LLC for willful violations of the Bank Secrecy Act and its implementing regulations. Canaccord is a broker-dealer headquartered in New York that provides market-making and trade execution services in securities primarily for institutional clients such as money managers, hedge funds, and financial institutions.

VIDEO: SAR Timelines for Continuing Activity

In this Compliance Clip (video), Adam explores a key BSA/AML question that many financial institutions face: how to handle the timeline when suspicious activity continues after an initial SAR filing. Drawing on longstanding guidance and more recent clarification, Adam walks through how institutions should think about timing and the practical challenges that can arise. If you've ever wondered how the continuing activity timeline actually works in practice, this quick overview will point you in the right direction. A transcript of this video is now available.

On February 26, 2026, FinCEN issued a proposed rule that, if finalized, would sever MBaer Merchant Bank AG (MBaer’s) access to the U.S. financial system as a result of its financial support to illicit actors linked to Russia and Iran.  If finalized, the proposed rule would prohibit covered U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, MBaer.

On February 13, 2026, FinCEN issued an order granting exceptive relief to covered financial institutions from certain requirements under FinCEN’s Customer Due Diligence Requirements for Financial Institutions rule. The order exempts covered financial institutions from the requirement to identify and verify the beneficial owners of a legal entity customer each time the customer opens a new account.

VIDEO: SAR Filings for Potential Structuring-Related Activity

In this Compliance Clip (video), Adam reviews FinCEN’s October 2025 FAQ guidance addressing whether a SAR is required for transactions near the $10,000 CTR threshold. He explains what the guidance says, how it applies to potential structuring activity, and what financial institutions should keep in mind for compliance. A transcript of this video is now available.