On April 17, 2026, InfoBytes reported that the CFPB has submitted the a final rule titled “Small Business Lending Data Collection Under the Equal Credit Opportunity Act Reconsideration” (RIN 3170-AB40) to the OMB’s Office of Information and Regulatory Affairs for review under Executive Order 12866 (as amended).

Apr 20
Apr 20 OCC Issues Updated Model Risk Management Guidance

Adam Witmer

Regulatory Update

On April 17, 2026, the OCC, in coordination with the Federal Reserve System and the FDIC, issued updated model risk management guidance for OCC-supervised institutions. This is part of the OCC’s ongoing efforts to reduce unnecessary burden and promote risk-based examination across institutions of all sizes.

Apr 20
Apr 20 FinCEN Publishes Its 2025 Year in Review

Adam Witmer

BSA, Regulatory Update

FinCEN recently published its FinCEN Year in Review for FY 2025. The Year in Review is intended to help stakeholders gain insight into both FinCEN’s efforts to support law enforcement and national security agencies and how financial information is used.

Apr 20
Apr 20 FinCEN Amends Special Measure on Certain Fund Transmittals Involving CIBanco

Adam Witmer

BSA, Regulatory Update

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.

Apr 16
Apr 16 FinCEN’s Rapid Response Program Intercepts Nearly $2 Billion for Cyber Fraud Victims

Adam Witmer

BSA, Regulatory Update

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.

Apr 14
Apr 14 FDIC Rescinds Supervisory Guidance on Multiple Re-Presentment NSF Fees

Adam Witmer

Regulatory Update

On April 10, 2025, the FDIC rescinded FIL-32-2023 titled FDIC Clarifying Supervisory Approach Regarding Supervisory Guidance on Multiple Re-Presentment NSF Fees, describing the FDIC’s supervisory approach relating to supervised institutions assessing multiple non-sufficient funds (NSF) fees arising from the re-presentment of the same unpaid transaction.

Apr 13
Apr 13 Treasury Proposes Rule to Enforce GENIUS Act Against Illicit Finance

Adam Witmer

BSA, Regulatory Update

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.

Apr 13
Apr 13 FinCEN Issues Proposed Rule to Reform AML/CFT Programs

Adam Witmer

Regulatory Update, BSA

On April 7, 2026, FinCEN issued a proposed rule intended to fundamentally reform financial institutions’ anti-money laundering and countering the financing of terrorism (AML/CFT) programs under the Bank Secrecy Act (BSA). According to FinCEN, the proposed rule would promote risk-based, reasonably designed programs and greater consistency in how banks are evaluated for effectiveness.

Apr 9
Apr 9 Agencies Issue Proposed Rule on AML/CFT

Adam Witmer

BSA, Regulatory Update

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.

Apr 9
Apr 9 Agencies Issue Final Rule Prohibiting the Use of Reputation Risk by Regulators

Adam Witmer

Regulatory Update

On April 7, 2026, the OCC and the FDIC jointly issued a final rule that codifies the elimination of reputation risk from their supervisory programs. The agencies believe that banking regulators’ use of the concept of reputation risk as a basis for supervisory criticisms increases subjectivity in banking supervision without adding material value from a safety and soundness perspective.

Apr 20
Apr 20 CFPB Submits Revised Section 1071 Rule to OMB for Review

Apr 20
Apr 20 OCC Issues Updated Model Risk Management Guidance

Apr 20
Apr 20 FinCEN Publishes Its 2025 Year in Review

Apr 20
Apr 20 FinCEN Amends Special Measure on Certain Fund Transmittals Involving CIBanco

Apr 16
Apr 16 FinCEN’s Rapid Response Program Intercepts Nearly $2 Billion for Cyber Fraud Victims

Apr 14
Apr 14 FDIC Rescinds Supervisory Guidance on Multiple Re-Presentment NSF Fees

Apr 13
Apr 13 Treasury Proposes Rule to Enforce GENIUS Act Against Illicit Finance

Apr 13
Apr 13 FinCEN Issues Proposed Rule to Reform AML/CFT Programs

Apr 9
Apr 9 Agencies Issue Proposed Rule on AML/CFT

Apr 9
Apr 9 Agencies Issue Final Rule Prohibiting the Use of Reputation Risk by Regulators

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