All in BSA

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.

On March 30, 2026, FinCEN issued a proposed rule to fully implement a whistleblower program by establishing a framework for offering incentives and protections to encourage individuals to report tips on fraud-related violations of the Bank Secrecy Act, U.S. sanctions programs administered by Treasury’s OFAC, and several other laws critical to safeguarding the U.S. financial system and national security. The proposed rule would implement section 6314 of the Anti-Money Laundering Act of 2020 and the Anti-Money Laundering Whistleblower Improvement Act.

VIDEO: SAR Timelines for Continuing Activity

In this Compliance Clip (video), Adam explores a key BSA/AML question that many financial institutions face: how to handle the timeline when suspicious activity continues after an initial SAR filing. Drawing on longstanding guidance and more recent clarification, Adam walks through how institutions should think about timing and the practical challenges that can arise. If you've ever wondered how the continuing activity timeline actually works in practice, this quick overview will point you in the right direction. A transcript of this video is now available.

On March 12, 2026, OFAC sanctioned six individuals and two entities for their roles in Democratic People’s Republic of Korea (DPRK) government-orchestrated information technology (IT) worker schemes that systematically defraud U.S. businesses. According to the OFAC, the scheme generates revenue to fund the DPRK’s weapons of mass destruction (WMD) programs, including nearly $800 million in 2024.