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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All in BSA
In this Compliance Clip (video), Adam discusses what financial institutions should consider when providing BSA/AML/CFT training to their board of directors. He reviews regulatory expectations and shares practical tips for developing effective board training that supports directors in fulfilling their oversight responsibilities. A transcript of this video is now available.
On October 21, 2026, the Treasury sanctioned Panama- and Greece-based law firm Karnakis and Karnakis as part of the Operation Economic Outcast. Accordion go the Treasury, Karnakis and Karnakis supported illicit Iranian shipping activity for years, indirectly aiding Tehran’s ability to generate revenue to fund its military, weapons, and nuclear programs.
On October 19, 2026, the Treasury announced that FinCEN has identified approximately $270 million in suspicious financial activity potentially linked to fraud against federal student aid programs. According to the Treasury, FinCEN has referred these findings to federal investigators to pursue potential fraud schemes targeting federal student aid programs and help ensure those responsible are held accountable.
On October 15, 2026, FinCEN issued an Alert asking financial institutions to report potential Iranian regime abuse of religious charity networks, including diversion of religious tithes, or khums. This action is part of Treasury’s Operation Economic Outcast, which targets Iran and its financial enablers.
On October 13, 2026, the Treasury announced enforcement actions imposing more than $1.21 billion in penalties against Bank of America for violations of anti-money laundering and sanctions laws. The actions include a $1.2 billion penalty from FinCEN, a $750 million penalty from the OCC, and an $11.6 million settlement with the OFAC.
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.
On October 1, 2026, the U.S. Department of the Treasury took unprecedented action against the A7 Network as part of Operation Economic Outcast. The A7 Network is a shadow banking network with ties to Russia used by the Iranian regime to evade sanctions.
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.
