All in Regulatory Update

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.

On March 6, 2026, FinCEN assessed an $80,000,000 civil money penalty against Canaccord Genuity LLC for willful violations of the Bank Secrecy Act and its implementing regulations. Canaccord is a broker-dealer headquartered in New York that provides market-making and trade execution services in securities primarily for institutional clients such as money managers, hedge funds, and financial institutions.

On February 26, 2026, FinCEN issued a proposed rule that, if finalized, would sever MBaer Merchant Bank AG (MBaer’s) access to the U.S. financial system as a result of its financial support to illicit actors linked to Russia and Iran.  If finalized, the proposed rule would prohibit covered U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, MBaer.

On February 19, 2026, the Federal Reserve Board announced that it will hold a hybrid public outreach meeting on March 26, 2026, as part of its review of regulations under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA). EGRPRA mandates that the Board, with public input, review its regulations every 10 years to identify outdated or unnecessarily burdensome requirements for certain supervised institutions.