FinCEN Issues Advisory on Health Care Fraud Schemes

Adam Witmer
Regulatory Update, BSA

On March 30, 2026, FinCEN issued an Advisory to urge financial institutions to be vigilant in identifying and reporting suspicious transactions potentially related to health care fraud schemes targeting Medicare, Medicaid, and other Federal and state health care benefit programs. The Advisory builds on Treasury’s work to combat the potentially billions of dollars in rampant health care and government benefits fraud in Minnesota and across the country.

FinCEN Proposes Rule to Pay Whistleblowers

Adam Witmer
BSA, Regulatory Update

On March 30, 2026, FinCEN issued a proposed rule to fully implement a whistleblower program by establishing a framework for offering incentives and protections to encourage individuals to report tips on fraud-related violations of the Bank Secrecy Act, U.S. sanctions programs administered by Treasury’s OFAC, and several other laws critical to safeguarding the U.S. financial system and national security. The proposed rule would implement section 6314 of the Anti-Money Laundering Act of 2020 and the Anti-Money Laundering Whistleblower Improvement Act.

VIDEO: SAR Timelines for Continuing Activity

VIDEO: SAR Timelines for Continuing Activity

Adam Witmer
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.

Second Court Affirms Support for CFPB Funding

Adam Witmer
Regulatory Update

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.

President Trump E.O. on Mortgage Market Reform

Adam Witmer
Regulatory Update

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.

Treasury Imposes Sanctions on Facilitators of DPRK IT Worker Fraud

Adam Witmer
BSA, 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.

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