Blog — Compliance Cohort

On October 21, 2025, the Senate proposed a bill that would raise the reporting thresholds for currency transaction reports and suspicious activity reports. If enacted, the bill would require the Treasury Department to adjust the thresholds for inflation every five years.

Oct 22
Oct 22 NCUA Proposes to Prohibit the Use of Reputation Risk

On October 21, 2025, the NCUA issued a a notice of proposed rulemaking to codify the elimination of reputation risk from its supervisory program. The FDIC and the OCC previously issued a joint proposal to formalize the elimination of reputation risk from their supervisory programs.

Oct 21
Oct 21 OCC Comptroller Gould Details Steps to Support Community Banks

On October 20, 2025, Comptroller of the Currency Jonathan Gould spoke at the American Bankers Association Annual Convention in Charlotte, North Carolina. Gould stated that his focus as a banking regulator is to rectify the regulatory overreach that has occurred since the 2008 financial crisis, especially regarding the community bank sector.

Oct 20
Oct 20 OCC Updates Fair Housing Lender Posters

On October 15, 2025, the OCC updated its Equal Housing Lender poster template in accordance with Executive Order 14224 “Designating English as the Official Language of the United States.” The E.O. designates English as the official language of the United States and instructs agencies to make decisions as they deem necessary to fulfill their respective missions and efficiently provide government services to the American people.

Oct 16
Oct 16 FinCEN Cuts Huione Group from U.S. Financial System

On October 15, 2025, FinCEN issued a final rule that severs Cambodia-based Huione Group from the U.S. financial system. Huione Group is a key player in laundering proceeds from cyber heists by North Korea and transnational criminal organizations in Southeast Asia involved in virtual currency investment scams, such as "pig butchering" scams.

Oct 15
Oct 15 U.S. and U.K. Targets Cybercriminal Networks in Southeast Asia

On October 14, 2025, the OFAC and FinCEN, in close coordination with the United Kingdom’s Foreign, Commonwealth, and Development Office (FCDO), took complementary actions against criminal networks responsible for targeting citizens of the United States and other allied nations through online scams and the laundering of stolen funds. OFAC has sanctioned 146 targets within the Prince Group Transnational Criminal Organization, a Cambodia-based network led by Chen Zhi, known for online investment scams targeting Americans and others globally.

Oct 13
Oct 13 FinCEN Issues FAQs to Clarify SAR Requirements

On October 9, 2025, FinCEN issued answers to four Frequently Asked Questions to clarify certain requirements related to suspicious activity reports (SARs). The FAQs were issued jointly with the Board, the FDIC, the NCUA, and the OCC.

Oct 9
Oct 9 FinCEN Renews Real Estate Geographic Targeting Orders

Regulatory Update, BSA

On October 9, 2025, FinCEN renewed its Geographic Targeting Orders (GTOs) that require US title insurance companies to identify natural persons behind shell companies used in non-financed purchases of residential real estate. The terms of the GTOs are effective beginning October 10, 2025.

Oct 8
Oct 8 OCC and FDIC Issue Proposals Aimed at Refocusing Bank Supervision