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 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.
On February 6, 2026, the OFAC launched its new online Voluntary Self-Disclosure Portal. The portal provides a streamlined, secure method for submitting voluntary self-disclosures of potential violations of OFAC-administered sanctions programs.
In this Compliance Clip (video), Adam discusses options for reporting a SAR to the board of directors when the SAR is on a director. He also discusses what to do if the SAR is on a member of senior management, like the president of the financial institution. This is a must-watch video for any BSA professional.
On January 12-13, 2026, FinCEN hosted the first meeting of the Transnational Organized Crime Working Group (TOC-WG). The group brings together representatives from 16 financial intelligence units (FIUs) committed to enhancing cooperation to identify and disrupt transnational organized crime.
On January 9, 2026, Secretary of the Treasury Scott Bessent announced several initiatives to combat rampant government benefits fraud in Minnesota, which has wasted billions of taxpayer dollars. The initiatives aim to protect Minnesota taxpayers and safeguard the financial system.
On December 31, 2025, FinCEN issued a final rule to extend the effective date of the rule establishing Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule) from January 1, 2026, until January 1, 2028.
On December 22, 2025, FinCEN announced a multi-tiered operation targeting more than 100 U.S. money services businesses (MSBs) operating along the southwest border to look for potential non-compliance with regulations designed to detect money laundering and combat illicit finance. According to FinCEN, the operation resulted in the issuance of six notices of investigation, dozens of examination referrals to the Internal Revenue Service (IRS), and over 50 compliance outreach letters.
On December 19, 2025, FinCEN held a FinCEN Exchange focused on denying individual Chinese money launders access to the U.S. and global financial systems. The Exchange was attended by global financial institutions, federal law enforcement agencies, and Treasury officials.
On December 9, 2025, FinCEN assessed a $3,500,000 civil money penalty against Paxful, Inc. and Paxful USA, Inc. for willful violations of the BSA. Paxful is a convertible virtual currency (CVC), peer-to-peer (P2P) trading platform.
On December 4, 2025, FinCEN issued a Financial Trend Analysis of ransomware incidents in BSA data from 2022 to 2024, totaling more than $2.1 billion in ransom payments. The report shifts the focus to the incident dates of each ransomware attack and provides greater visibility into the activities of ransomware actors.
