Risky Business Recap
Quick takes on emerging risk and
enforcement trends
The Arc-Serv Advantage
Spotlight: FinCEN Moves to Pay Whistleblowers for BSA & Sanctions Violations
Snapshot: On March 30, 2026, FinCEN issued a Notice of Proposed Rulemaking (NPRM) to fully implement its long‑awaited AML & sanctions whistleblower rewards program. The proposal would allow eligible whistleblowers to receive 10%–30% of collected penalties tied to...
Spotlight: OFAC Penalizes Brokerage Firm for Sanctions Control Failures
Snapshot: On March 17, 2026, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced a $1.1 million settlement with TradeStation Securities, Inc. for nearly 500 apparent sanctions violations involving customers located in Iran, Syria, and Crimea. OFAC...
Spotlight: FinCEN Issues Record‑Setting $80M BSA Penalty Against Broker‑Dealer
Snapshot: On March 6, 2026, FinCEN assessed an $80 million civil money penalty against Canaccord Genuity LLC for willful violations of the Bank Secrecy Act, marking the largest BSA penalty ever imposed on a broker‑dealer. The enforcement action cited failures related...
Spotlight: Treasury Releases 2026 National Risk Assessments on Illicit Finance
Snapshot: On March 7, 2026, the U.S. Department of the Treasury released its latest National Risk Assessments for Money Laundering, Terrorist Financing, and Proliferation Financing. The reports highlight evolving risks tied to fraud, transnational criminal...
Spotlight: FFIEC Drops New BSA/AML Manual Updates
Snapshot: On February 27, 2026, the FFIEC released updates to multiple sections of the BSA/AML Examination Manual, including Suspicious Activity Reporting, Payable Through Accounts, Electronic Banking, and Nondeposit Investment Products. The revisions also formally...
Spotlight: Treasury Moves to Cut Off Swiss Bank MBaer from U.S. Financial System
Snapshot: On February 26, 2026, the U.S. Department of the Treasury, through FinCEN, issued an NPRM that would sever MBaer Merchant Bank AG’s access to the U.S. financial system due to its alleged financial support to illicit actors linked to Russia and Iran. If...
Spotlight: FATF Adds Kuwait & Papua New Guinea to the Grey List
Snapshot: On February 13, 2026, the FATF released its newest update to the jurisdictions under increased monitoring—commonly called the grey list—adding Kuwait and Papua New Guinea. No countries were removed during this review cycle. Why it Matters: Grey‑listed...
Spotlight: FinCEN Streamlines CDD Requirements
Snapshot: Big news from Friday—On February 13, 2026, FinCEN issued an order granting exceptive relief from portions of the 2016 Customer Due Diligence (CDD) Rule. The relief removes the requirement for financial institutions to re‑identify and re‑verify beneficial...
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