Risky Business Recap
Quick takes on emerging risk and
enforcement trends
The Arc-Serv Advantage
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...
Spotlight: Rapid OFAC Sanctions Updates Put BSA Operations Under Pressure
Snapshot: Between April 29 and May 1, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued multiple same‑day sanctions list updates, along with amended General Licenses, FAQs, and compliance guidance. Many of these actions were...
Spotlight: OCC Resets Expectations for BSA/AML Model Risk Management
Snapshot: On April 17, 2026, the OCC issued Bulletin 2026‑13, releasing revised interagency Model Risk Management (MRM) guidance and rescinding prior BSA/AML‑specific model guidance, including OCC Bulletin 2021‑19. The updated guidance reinforces a risk‑based,...
Spotlight: Federal Regulators Eliminate Use of Reputation Risk in Supervision
Snapshot: On April 7, 2026, federal banking regulators issued a final rule formally prohibiting examiners from using “reputation risk” as a standalone basis for supervisory criticism. The rule directs agencies to focus supervision on measurable financial, operational,...
Spotlight: FinCEN Proposes a Fundamental Reset of AML/CFT Program Expectations
Snapshot: On April 7, 2026, FinCEN issued a sweeping Notice of Proposed Rulemaking (NPRM) that would fundamentally reform how financial institutions design, implement, and are examined on their AML/CFT programs. The proposal shifts supervisory focus away from...
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...
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