All in BSA

On May 22, 2026, the FDIC Board of Directors approved a proposed rule that would implement BSA and sanctions compliance standards applicable to FDIC-supervised permitted payment stablecoin issuers (PPSIs) as required by the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).  The FDIC is the primary Federal regulator of PPSIs that are subsidiaries of insured state nonmember banks and state savings associations approved by the FDIC to issue payment stablecoins.

On May 19, 2026, President Donald Trump signed an executive order aimed at strengthening protections against financial fraud, illicit finance, and credit risks tied to unauthorized employment and cross-border financial activity. The order directs several federal agencies, including the Treasury, the CFPB, and federal banking regulators, to issue guidance and consider regulatory changes impacting banks, credit unions, and other financial institutions.

On May 6, 2026, FinCEN updated several of its Q&As on Customer Due Diligence Requirements for Financial Institutions to align with the exceptive relief order issued on February 13, 2026. The reissued FAQs also consolidate three sets of previously issued FAQs published in 2016, 2018, and 2020 into a single document.

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.