All in BSA

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.

VIDEO: Reporting a SAR on a Director to the Board

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 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.