Risky Business Recap
Quick takes on emerging risk and
enforcement trends
The Arc-Serv Advantage
Spotlight: Regulators Clarify What Banks Can Tell Customers During SAR Investigations
Snapshot: On September 2, 2026, FinCEN, along with the FRB, FDIC, NCUA, and OCC, issued a joint statement clarifying how financial institutions may communicate with customers about potentially fraudulent transactions, suspicious activity, and account closures without...
Spotlight: FinCEN Highlights Growing Risks Tied to Hospice and Healthcare Fraud
Snapshot: On August 19, 2026, FinCEN announced that it convened financial institutions and law enforcement to discuss emerging healthcare benefits fraud schemes, including the exploitation of hospice care services. Participants reviewed evolving fraud typologies,...
Spotlight: FinCEN Identifies Nearly $5 Billion Linked to Suspected Human Smuggling
Snapshot: On August 13, 2026, FinCEN issued a Financial Trend Analysis showing that financial institutions flagged nearly $5 billion in transactions linked to suspected human smuggling activity between 2023 and 2025. The report identified common patterns, including...
Spotlight: FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for U.S. Companies
Snapshot: On August 11, 2026, the U.S. Department of the Treasury announced that FinCEN has issued a final rule permanently removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency...
Spotlight: FinCEN’s Historic UBS Enforcement Action
Snapshot: On August 3, 2026, FinCEN assessed a $125 million civil money penalty against UBS Financial Services Inc. for willful violations of the Bank Secrecy Act (BSA). FinCEN stated that the firm failed to adequately address previously identified AML deficiencies,...
Spotlight: Treasury Targets Infrastructure Supporting Ransomware Attacks
Snapshot: On July 13, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctioned two individuals and one entity that allegedly provided infrastructure and malware-obfuscation services used by ransomware actors targeting Americans....
Spotlight: Regulators Encourage Expanded Fraud Information Sharing
Snapshot: On July 9, 2026, the OCC highlighted FinCEN's updated Section 314(b) guidance, which clarifies that financial institutions may voluntarily share information about suspected fraud, in addition to traditional money laundering and terrorist financing activity,...
Spotlight: Federal Reserve Advances Risk-Based AML Expectations
Snapshot: On July 7, the Federal Reserve requested comment on proposed amendments to its anti-money laundering program requirements, which would require supervised banks to maintain AML/CFT programs reasonably designed to identify, assess, and mitigate illicit finance...
Spotlight: FinCEN Warns Banks About Cartel-Linked Fuel Smuggling Schemes
Snapshot: On June 30, 2026, the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) issued a supplemental alert warning financial institutions about fuel smuggling and tax evasion schemes connected to the Cartel de Jalisco Nueva Generación (CJNG) and other...
Spotlight: FinCEN Moves to Expand Section 311 Restrictions on H-Pay Service PLC
Snapshot: On June 23, 2026, FinCEN proposed amending its October 2025 final rule concerning the Huione Group to include H-Pay Service PLC and any successor entity. According to Treasury, H-Pay is associated with financial activity linked to cyber-enabled fraud,...
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