Risky Business Recap
Quick takes on emerging risk and
enforcement trends
The Arc-Serv Advantage
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...
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...
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