All in BSA

On October 8, 2026, the OCC announced a cease-and-desist order and a $350 million civil money penalty against American Express National Bank, Sandy, Utah, for deficiencies in the bank’s BSA and AML compliance program. The OCC found that the bank failed to establish and maintain a BSA/AML compliance program reasonably designed to assure and monitor compliance with the BSA and its implementing regulations.

On October 5, 2026, FinCEN announced that it is withdrawing two proposed rules that would have imposed certain regulatory requirements on financial institutions related to certain digital assets, specifically convertible virtual currencies. This action is part of ongoing efforts to ensure digital asset regulations are fit-for-purpose and in accordance with Trump Administration’s deregulatory agenda.

On October 1, 2026, FinCEN issued an Alert to urge financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity, involving the A7 Network. The A7 Network is a global wholesale sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors, including Iran and its terrorist proxies.

VIDEO: BSA SAR Continuing Activity Reviews

In this Compliance Clip (video), Adam discusses FinCEN’s October 2025 FAQ addressing continuing activity reviews after a suspicious activity report (SAR) has been filed. He explains why this clarification has raised questions for financial institutions and explores what BSA/AML/CFT teams should consider when monitoring for continued suspicious activity. A transcript of this video is now available.

On September 8, 2026, FinCEN issued an Alert to assist financial institutions in identifying and reporting procurement networks supporting Iran’s aviation industry, which the Iranian regime uses to transport weapons, funds, and personnel in support of the Islamic Revolutionary Guard Corps (IRGC) and its terrorist proxies. In conjunction with the alert, OFAC sanctioned 36 targets, including 27 Iranian airlines, for supporting Iran’s aviation sector, which the regime uses to move weapons, personnel, and illicit cargo. 

On September 3, 2026, FinCEN published an analysis and an alert to financial institutions to be vigilant about digital asset investment scams perpetrated by overseas scam centers. According to FinCEN, these digital asset scams are largely driven by Southeast Asian criminal networks, which operate industrial-scale scam compounds and leverage vast networks of criminal actors to facilitate and profit from scams.