FinCEN Amends Special Measure on Certain Fund Transmittals Involving CIBanco

Adam Witmer
BSA, Regulatory Update

On April 16, 2026, FinCEN issued an order amending its June 2025 order finding that CIBanco S.A., Institución de Banca Multiple (CIBanco), is a financial institution operating outside of the United States that is of primary money laundering concern in connection with illicit opioid trafficking and imposing a special measure prohibiting certain transmittals of funds involving CIBanco. 

VIDEO: Reporting a SAR on a Director

VIDEO: Reporting a SAR on a Director

Adam Witmer
BSA

In this Compliance Clip (video), Adam explores a challenging scenario involving Suspicious Activity Report (SAR) obligations when the subject of the report is a member of the board itself. Through a real-world example, Adam highlights the tension between regulatory reporting requirements and strict confidentiality rules. Adam also points toward key guidance on how institutions should navigate this sensitive situation without breaching compliance expectations.

FinCEN’s Rapid Response Program Intercepts Nearly $2 Billion for Cyber Fraud Victims

Adam Witmer
BSA, Regulatory Update

On April 15, 2026, FinCEN published a Fact Sheet detailing that FinCEN’s Rapid Response Program (RRP) has facilitated the interdiction of $1.8 billion and the recovery of over $1 billion in stolen proceeds on behalf of 5,790 U.S. victims. RRP is a partnership between FinCEN, U.S. law enforcement, and foreign partners working together to help victims and their financial institutions recover stolen funds sent abroad as the result of cyber-enabled fraud.

Treasury Proposes Rule to Enforce GENIUS Act Against Illicit Finance

Adam Witmer
BSA, Regulatory Update

On April 8, 2026, FinCEN and the OFAC issued a joint proposed rule to implement provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) in countering illicit finance. The GENIUS Act directs the Treasury to issue regulations that would treat permitted payment stablecoin issuers (PPSIs) as financial institutions for purposes of the BSA and impose anti-money laundering obligations on PPSIs.  

VIDEO: How to Conduct BSA Training for Directors

VIDEO: How to Conduct BSA Training for Directors

Adam Witmer
BSA

In this Compliance Clip (video), Adam discusses how financial institutions can approach BSA training for their board of directors in a way that aligns with examiner expectations while remaining practical and effective. Adam highlights key considerations around balancing foundational knowledge with ongoing updates, as well as tailoring content to a board-level audience. A transcript of this video is now available.

Agencies Issue Proposed Rule on AML/CFT

Adam Witmer
BSA, Regulatory Update

On April 7, 2026, the FDIC, the OCC, and the NCUA jointly issued a proposed rule to amend the respective requirements for their supervised institutions to establish and maintain effective risk-based anti-money laundering and countering the financing of terrorism (AML/CFT) programs designed to identify, assess, and mitigate risks of illicit finance. The amendments are intended to align each agency’s AML/CFT rules with changes concurrently proposed by FinCEN.

Agencies Issue Final Rule Prohibiting the Use of Reputation Risk by Regulators

Adam Witmer
Regulatory Update

On April 7, 2026, the OCC and the FDIC jointly issued a final rule that codifies the elimination of reputation risk from their supervisory programs. The agencies believe that banking regulators’ use of the concept of reputation risk as a basis for supervisory criticisms increases subjectivity in banking supervision without adding material value from a safety and soundness perspective. 

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