Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
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In this Compliance Clip (video), Adam reviews FinCEN’s October 2025 FAQ guidance addressing whether a SAR is required for transactions near the $10,000 CTR threshold. He explains what the guidance says, how it applies to potential structuring activity, and what financial institutions should keep in mind for compliance. A transcript of this video is now available.
On February 11, 2026, the NCUA issued a proposed rule outlining the framework for applicants seeking NCUA approval to become a permitted payment stablecoin issuer. The proposed rule marks the NCUA’s first step in implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).
On February 10, 2026, the ABA Banking Journal reported that almost 200 Democratic and independent members of Congress filed an amicus brief urging the courts to halt what they said was the Trump administration’s attempt to dismantle the CFPB. The lawmakers argue that the Trump administration’s actions are unconstitutional because only Congress has the authority to create and abolish government agencies.
On February 6, 2026, the FDIC announced a 90-day extension to the comment period on the agency’s notice of proposed rulemaking (NPR) that would implement the application provisions under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) for FDIC-supervised state nonmember banks and state savings associations seeking to issue payment stablecoins through a subsidiary.
On February 6, 2026, the OFAC launched its new online Voluntary Self-Disclosure Portal. The portal provides a streamlined, secure method for submitting voluntary self-disclosures of potential violations of OFAC-administered sanctions programs.
In this Compliance Clip, Adam provides a high-level overview of the CFPB’s November 2025 proposed revisions to the Section 1071 small business data collection rule. While the proposal signals a significant shift from the March 2023 final rule, key details remain unsettled and could have meaningful implications for financial institutions. Watch the video as Adam briefly discusses what’s changing, what’s still uncertain, and why these proposed revisions deserve close attention.
On February 3, 2026, Massachusetts Attorney General Andrea Joy Campbell filed a lawsuit against cryptocurrency kiosk operator Bitcoin Depot Inc. and Bitcoin Depot Operating LLC for allegedly using misleading and deceptive sales tactics to overcharge consumers, knowingly facilitating crypto scams, refusing to issue refunds to scam victims, and deceiving investors about the level of scam activity on Bitcoin Depot kiosks.
On January 30, 2026, President Donald Trump announced his nomination of Kevin Warsh to serve as Chairman of the Board of Governors of the Federal Reserve System. Mr. Warsh previously served as a member of the Federal Reserve’s Board of Governors, becoming the youngest individual to hold the position.
On February 23, 2026, the Federal Reserve Board issued a proposed rule to codify the removal of reputation risk from its supervision of banks. The Board’s action follows its earlier actions regarding that removal and reiterates its policy against penalizing or prohibiting an institution from banking a customer engaged in legal activity.
On January 29, 2026, the FDIC issued a final rule amending its signage requirements for insured depository institutions' (IDIs) digital deposit-taking channels and automated teller machines (ATMs) and like devices. The final rule addresses implementation issues and sources of potential confusion raised following the adoption of signage requirements for these banking channels in 2023.
