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.

Sep 8
Sep 8 NCUA Removes Disparate Impact References From Its Manuals

Adam Witmer

Regulatory Update, Fair Lending

On September 4, 2025, the NCUA announced its removal of all references to disparate impact liability from its Fair Lending Guide and other issuances. These updates are in line with the White House Executive Order 14281, which aims to restore equality of opportunity and meritocracy by directing federal agencies to remove the use of disparate impact liability across all contexts.

Sep 3
Sep 3 FDIC Removes Disparate Impact from the Consumer Compliance Examination Manual

Adam Witmer

Regulatory Update, Fair Lending

On August 29, 2025, the FDIC updated sections of the Consumer Compliance Examination Manual. The manual was updated to reflect that the FDIC will evaluate potential discrimination under the Equal Credit Opportunity Act and Fair Housing Act only through evidence of disparate treatment.

Sep 2
Sep 2 Fed Special Fraud Issue of the Consumer Compliance Outlook

Adam Witmer

Regulatory Update

The Federal Reserve Board has recently published a special edition of the Consumer Compliance Outlook focusing on fraud. The special issue discusses several fraud topics, including the banking agencies’ recent request for information on payment and check fraud.

Sep 1
Sep 1 CFPB Issues Proposed Rule on Supervisory Designation Proceedings

Adam Witmer

Regulatory Update

On August 26, 2025, the CFPB issued a proposed rule adopting a standard definition of “risks to consumers with regard to the offering or provision of consumer financial products or services” that will bind the Bureau in proceedings to designate nonbank covered persons for Bureau supervision. The CFPB stated that this will ensure that the Bureau acts within the bounds of its statutory authority and provide clarity to institutions about the standard it applies.

Aug 29

Aug 29 VIDEO: Minimum CIP Requirements

Adam Witmer

BSA

In this Compliance Clip (video), Adam talks about the minimum requirements for a financial institution’s Customer Identification Program. This is a BSA topic. A transcript of this video is now available.

Aug 28
Aug 28 FinCEN Issues Advisory and FTA on Chinese Money Laundering Networks

Adam Witmer

BSA, Regulatory Update

On August 28, 2025, FinCEN issued an Advisory to urge financial institutions to be vigilant in detecting the use of Chinese money laundering networks (CMLNs) by Mexico-based drug cartels, including several designated as Foreign Terrorist Organizations. It also published a Financial Trend Analysis (FTA) highlighting the scope and breadth of CMLN activity in the United States.

Aug 27
Aug 27 OFAC Removes Syrian Sanctions Regulations

Adam Witmer

Regulatory Update, BSA

On August 26, 2025, the OFAC issued a final rule that removes the Syrian Sanctions Regulations from the Code of Federal Regulations. This action is a result of the termination of the national emergency on which the regulations were based and further changes to the policy of the United States towards Syria.

Aug 25
Aug 25 CFPB Seeks Comment on Section 1033 Implementation

Adam Witmer

Regulatory Update

On August 22, 2025, the CFPB issued an advance notice of proposed rulemaking to inform its consideration of four issues related to the implementation of section 1033 of the Dodd-Frank Act. Section 1033 outlines the requirement for “covered persons” to make financial transaction data available to consumers and authorized third parties upon request, under rules prescribed by the Bureau.

Aug 25
Aug 25 Treasury Extends Effective Dates for Fentanyl Countermeasures

Adam Witmer

BSA, Regulatory Update

On August 19, 2025, FinCEN extended the effective dates for orders issued on June 25, 2025, prohibiting certain transmittal of funds involving three Mexico-based financial institutions. Covered financial institutions will now have until October 20, 2025, to implement the orders prohibiting certain transmittal of funds involving CIBanco S.A., Institución de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector).

Sep 8
Sep 8 FinCEN Issues Guidance on Cross-Border Information Sharing

Sep 8
Sep 8 NCUA Removes Disparate Impact References From Its Manuals

Sep 3
Sep 3 FDIC Removes Disparate Impact from the Consumer Compliance Examination Manual

Sep 2
Sep 2 Fed Special Fraud Issue of the Consumer Compliance Outlook

Sep 1
Sep 1 CFPB Issues Proposed Rule on Supervisory Designation Proceedings

Aug 29 VIDEO: Minimum CIP Requirements

Aug 28
Aug 28 FinCEN Issues Advisory and FTA on Chinese Money Laundering Networks

Aug 27
Aug 27 OFAC Removes Syrian Sanctions Regulations

Aug 25
Aug 25 CFPB Seeks Comment on Section 1033 Implementation

Aug 25
Aug 25 Treasury Extends Effective Dates for Fentanyl Countermeasures

View all membership plans.