Risky Business Recap
Quick takes on emerging risk and
enforcement trends
The Arc-Serv Advantage
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,...
Spotlight: FinCEN Expands Fraud-Fighting Expectations Through Information Sharing Guidance
Snapshot: On June 12, 2026, FinCEN issued updated guidance clarifying how financial institutions can share information to identify and combat fraud under Section 314(b) of the USA PATRIOT Act. The update reinforces information sharing as a key tool in detecting and...
Spotlight: New Interagency Rule Standardizes Financial Data Reporting
Snapshot: On June 11, 2026, federal regulators (including the OCC, Federal Reserve, FDIC, and CFPB) issued a joint final rule under the Financial Data Transparency Act requiring the development of standardized data formats for regulatory reporting across agencies. The...
Spotlight: FinCEN Flags Payroll Fraud Risks Tied to Unauthorized Workers
Snapshot: On June 5, 2026, FinCEN issued a new advisory urging financial institutions to identify and report suspicious activity tied to payroll fraud, identity theft, and money laundering linked to the employment of unauthorized workers. The advisory follows a May...
Spotlight: FDIC Advances BSA and Sanctions Standards for Stablecoin Issuers
Snapshot: On May 22, 2026, the FDIC approved a proposal establishing Bank Secrecy Act (BSA) and sanctions compliance expectations for FDIC‑supervised banks involved with payment stablecoin issuers. The proposal aligns with broader regulatory efforts to define...
Spotlight: OFAC Issues Wave of New Sanctions Designations Across Multiple Programs
Snapshot: Between May 18–21, 2026, OFAC issued multiple updates to its sanctions lists, including counterterrorism, counternarcotics, and Iran-related designations. These updates reflect continued enforcement activity and frequent changes to the SDN List impacting...
Spotlight: FinCEN Flags Iran‑Linked Networks Using Front Companies and Digital Assets
Snapshot: On May 11, 2026, FinCEN issued an alert detailing how Iran’s Islamic Revolutionary Guard Corps (IRGC) is using front companies, financial facilitators, and digital asset infrastructure to evade sanctions and move illicit funds. The alert highlights...
Spotlight: OCC Highlights Rising Fraud and Operational Risk
Snapshot: On May 7, 2026, the Office of the Comptroller of the Currency released its Spring 2026 Semiannual Risk Perspective, outlining key risks facing the federal banking system. The report identifies increasing cyber‑enabled fraud, scams, and operational risk...
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