Risky Business Recap
Quick takes on emerging risk and
enforcement trends
The Arc-Serv Advantage
Spotlight: Stablecoin Regulation Moves From Legislation to Implementation
Snapshot: On October 21, 2026, the OCC issued its final rule implementing key provisions of the GENIUS Act, establishing requirements for permitted payment stablecoin issuers, foreign payment stablecoin issuers under OCC jurisdiction, and certain custody activities...
Spotlight: $1.2 Billion Wake-Up Call for BSA/AML Compliance
Snapshot: On October 13, 2026, FinCEN assessed a $1.2 billion penalty against Bank of America for BSA violations, including failures involving its AML program, correspondent banking due diligence, and suspicious activity reporting. The coordinated action also included...
Spotlight: FinCEN Withdraws Digital Asset Rulemakings for Unhosted Wallets and Crypto Mixers
Snapshot: On October 5, 2026, FinCEN announced the withdrawal of two proposed rules that would have imposed additional recordkeeping, verification, and reporting requirements on certain digital asset transactions involving unhosted wallets and convertible virtual...
Spotlight: FinCEN Shares New Intelligence With Banks to Disrupt Terrorist Financing Networks
Snapshot: On September 16, 2026, FinCEN convened a FinCEN Exchange with global financial institutions as part of Operation Economic Outcast. Treasury provided participating institutions with intelligence on financial networks, facilitators, correspondent banking...
Spotlight: OFAC Consolidates Sanctions Penalty and Enforcement Provisions into a Single Regulatory Framework
Snapshot: On September 24, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced new Sanctions Penalties Regulations, which consolidate sanctions enforcement procedures, penalty information, and the rights of persons under...
Spotlight: FinCEN Identifies $17.5 Billion in Potential Health Care Fraud Through BSA Reporting
Snapshot: On September 9, 2026, FinCEN released a new report showing that financial institutions identified approximately $17.5 billion in suspicious activity potentially linked to health care fraud through Bank Secrecy Act (BSA) reporting. The analysis reviewed more...
Spotlight: FinCEN Clarifies Use of Digital IDs for Customer Identification
Snapshot: On September 8, 2026, FinCEN issued Frequently Asked Questions Regarding Treatment of Verifiable Digital Credentials Under the Customer Identification Program Rule, which clarified how banks and credit unions may use state-issued mobile driver's licenses...
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...
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