On December 10, 2025, the CFPB published a Data Spotlight on Buy Now Pay Later that examined market trends and key metrics in the BNPL market for 2022 and 2023. The data demonstrates that BNPL products remain a popular financing choice with consumers.

Dec 15
Dec 15 OCC Releases Findings on Large Banks' Debanking Activities

Adam Witmer

Regulatory Update

On December 10, 2025, the OCC released preliminary findings from its supervisory review of debanking activities at the nine largest national banks it supervises: JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank. The supervisory review was carried out by the OCC in accordance with the President’s Executive Order Guaranteeing Fair Banking for All Americans to assess if any institutions debanked or discriminated against customers based on their political or religious beliefs or lawful business activities.

Dec 15
Dec 15 OCC Confirms Bank Authority for Riskless Crypto Transactions

Adam Witmer

Regulatory Update

On December 9, 2025, the OCC published Interpretive Letter 1188 confirming that a national bank may engage in riskless principal crypto-asset transactions as part of the business of banking. These transactions occur when a bank buys an asset from one party and immediately resells it to another based on a matching order.

Dec 11
Dec 11 NCUA Publishes 4 Proposed Rules

Adam Witmer

Regulatory Update

On December 10, 2025, the NCUA announced the first round of proposed regulatory changes associated with a new initiative to review and potentially revise the agency’s regulations. The NCUA’s “Deregulation Project” follows Executive Order 14192 Unleashing Prosperity Through Deregulation.

Dec 10
Dec 10 FinCEN Fines Paxful $3.5 Million for Facilitating Suspicious Activity

Adam Witmer

BSA, Regulatory Update

On December 9, 2025, FinCEN assessed a $3,500,000 civil money penalty against Paxful, Inc. and Paxful USA, Inc. for willful violations of the BSA. Paxful is a convertible virtual currency (CVC), peer-to-peer (P2P) trading platform.

Dec 8
Dec 8 FinCEN Issues Financial Trend Analysis on Ransomware

Adam Witmer

Regulatory Update, BSA

On December 4, 2025, FinCEN issued a Financial Trend Analysis of ransomware incidents in BSA data from 2022 to 2024, totaling more than $2.1 billion in ransom payments. The report shifts the focus to the incident dates of each ransomware attack and provides greater visibility into the activities of ransomware actors.

Dec 2
Dec 2 FDIC Extends Official Signs and Advertising Requirements Compliance

Adam Witmer

Regulatory Update

On November 25, 2025, the FDIC announced that it is extending the compliance date for the requirements to display the FDIC official digital sign on an insured depository institution’s (IDI’s) digital deposit-taking channels and like devices from March 1, 2026, to January 1, 2027. The extension aligns the compliance date with the FDIC’s proposal issued earlier this year that would make adjustments to those provisions.

Dec 2
Dec 2 OCC Establishes Community Bank Minimum BSA/AML Exam Procedures

Adam Witmer

BSA, Regulatory Update

On November 24, 2025, the OCC issued the Community Bank Minimum Bank Secrecy Act (BSA/AML) Examination Procedures for BSA/AML compliance examinations. The new Community Bank Procedures will become effective for examinations beginning February 1, 2026.

Dec 1
Dec 1 CFPB Publishes FDCPA 2025 Annual Report

Adam Witmer

Regulatory Update

On November 21, 2025, the CFPB published its Fair Debt Collection Practices Act Annual (FDCPA) Report for 2025. The report includes a summary of the CFPB's activities to administer the FDCPA in 2024 and activities related to debt collection that were conducted by the Federal Trade Commission.

Nov 26
Nov 26 FATF Updates List of Deficient Countries (11/21/25)

Paula Parras

BSA, Regulatory Update

On November 21, 2025, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT/CPF deficiencies. This advisory informs U.S. financial institutions about jurisdictions the Financial Action Task Force (FATF) has identified as having strategic deficiencies in their anti-money laundering, countering the financing of terrorism, and countering the financing of proliferation (AML/CFT/CPF) regimes.

Dec 15
Dec 15 CFPB Publishes Buy Now Pay Later Data Spotlight

Dec 15
Dec 15 OCC Releases Findings on Large Banks' Debanking Activities

Dec 15
Dec 15 OCC Confirms Bank Authority for Riskless Crypto Transactions

Dec 11
Dec 11 NCUA Publishes 4 Proposed Rules

Dec 10
Dec 10 FinCEN Fines Paxful $3.5 Million for Facilitating Suspicious Activity

Dec 8
Dec 8 FinCEN Issues Financial Trend Analysis on Ransomware

Dec 2
Dec 2 FDIC Extends Official Signs and Advertising Requirements Compliance

Dec 2
Dec 2 OCC Establishes Community Bank Minimum BSA/AML Exam Procedures

Dec 1
Dec 1 CFPB Publishes FDCPA 2025 Annual Report

Nov 26
Nov 26 FATF Updates List of Deficient Countries (11/21/25)

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