All in Regulatory Update

On September 10, 2025, Comptroller of the Currency Jonathan V. Gould issued a statement at the Financial Stability Oversight Council (FSOC) meeting about the OCC's work to reset the risk tolerance for the federal banking system. Comptroller Gould discussed the OCC’s work to review the agency’s post-2008 chartering, regulatory, and supervisory framework to ensure the federal banking system remains relevant and fulfills its mission.

On September 8, 2025, the FDIC updated chapter four of its Formal and Informal Enforcement Actions Manual, entitled Cease-and-Desist Actions, regarding the agency’s minimum standards for terminating cease-and-desist and consent orders issued under Section 8(b) of the Federal Deposit Insurance Act. The manual provides direction for professional staff related to the work necessary to pursue formal and informal enforcement actions. 

On September 8, 2025, FinCEN reiisued a modified Geographic Targeting Order (GTO) to combat illicit cartel and other criminal activity, including money laundering, along the southwest border of the United States. FinCEN previously issued a notice of a GTO requiring certain money services businesses along the southwest border to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions.

On September 5, 2025, FinCEN issued guidance to encourage and promote appropriate, voluntary cross-border sharing of information between and among financial institutions, including appropriate foreign financial institutions. According to FinCEN, the Guidance aims to help combat the threats posed by money laundering, terrorist financing, and other illicit finance activity, including from drug trafficking organizations, foreign terrorist organizations, and fraudsters.