All in BSA

On April 16, 2026, FinCEN issued an order amending its June 2025 order finding that CIBanco S.A., Institución de Banca Multiple (CIBanco), is a financial institution operating outside of the United States that is of primary money laundering concern in connection with illicit opioid trafficking and imposing a special measure prohibiting certain transmittals of funds involving CIBanco. 

VIDEO: Reporting a SAR on a Director

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.

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 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.  

VIDEO: How to Conduct BSA Training for Directors

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 March 31, 2026, the OFAC issued a sanctions advisory to highlight sanctions risks arising from sham transactions used to evade sanctions and to identify factors to consider when evaluating whether property may be the subject of a sham transaction. Sham transactions occur when blocked individuals use intermediaries to falsely give up property to evade sanctions while still retaining an interest in it.

On March 30, 2026, FinCEN issued an Advisory to urge financial institutions to be vigilant in identifying and reporting suspicious transactions potentially related to health care fraud schemes targeting Medicare, Medicaid, and other Federal and state health care benefit programs. The Advisory builds on Treasury’s work to combat the potentially billions of dollars in rampant health care and government benefits fraud in Minnesota and across the country.