Blog — Compliance Cohort

BSA

In this Compliance Clip (video), Adam explores a key BSA/AML question that many financial institutions face: how to handle the timeline when suspicious activity continues after an initial SAR filing. Drawing on longstanding guidance and more recent clarification, Adam walks through how institutions should think about timing and the practical challenges that can arise. If you've ever wondered how the continuing activity timeline actually works in practice, this quick overview will point you in the right direction. A transcript of this video is now available.

Mar 17
Mar 17 Second Court Affirms Support for CFPB Funding

On March 16, 2026, the ABA Banking Journal reported that a federal judge had ruled that the Trump administration must continue funding the Consumer Financial Protection Bureau. U.S. District Judge Edward Davila's ruling represents another strike against President Donald Trump's handling of Consumer Financial Protection Bureau (CFPB) funding, which he has argued should be eliminated.

Mar 16
Mar 16 President Trump E.O. on Mortgage Market Reform

On March 13, 2026, President Donald Trump issued an Executive Order outlining a broad policy shift aimed at reducing regulatory burden in the U.S. mortgage market, with a particular emphasis on community banks and smaller financial institutions. The E.O. directs federal agencies to reassess existing mortgage-related regulations and supervisory practices to improve credit access, enhance market competition, and modernize operational frameworks, while maintaining core consumer protection principles.

Mar 12
Mar 12 Treasury Imposes Sanctions on Facilitators of DPRK IT Worker Fraud

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.

Mar 11
Mar 11 NCUA’s Seventh Round of Deregulation Proposals

On March 10, 2026, the NCUA announced its seventh round of proposed regulatory changes associated with its Deregulation Project. NCUA is requesting comments on one proposal that would clarify agency guidance or eliminate unduly burdensome or duplicative requirements in the Code of Federal Regulations.

Mar 11
Mar 11 FinCEN Extends and Expands SW Border GTO for MSBs

On March 10, 2026, FinCEN issued a new Geographic Targeting Order (GTO) imposing recordkeeping and reporting requirements on certain money services businesses (MSBs) along the southwest border. The GTO effectively extends a similar order issued on September 10, 2025 and expired on March 6, 2026.

Mar 9
Mar 9 FinCEN Imposes $80M Penalty on Canaccord Genuity for BSA Violations

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.

Mar 9
Mar 9 FFIEC Removes Reputational Risk in BSM/AML Manual

In late February, the FFIEC released updates to the BSA/AML Examination Manual to remove references to reputational risk. The action is consistent with Executive Order 14331, which required banking regulators to remove the use of reputation risk or equivalent concepts that could result in politicized or unlawful debanking.

Mar 4
Mar 4 OCC Issues Final Rules to Reduce Regulatory Burden for Community Banks