Regulatory Alerts

The Federal Reserve has officially set June 27, 2025, as the release date for this year’s bank stress test results. With the new testing framework taking effect just days earlier (June 15), this announcement carries heightened importance. Financial institutions will face the public reveal of how well they hold up under significantly tougher standards introduced in this year's update.

On June 16, 2025, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2025‑12, a Request for Information (RFI) aimed at gathering public feedback on strategies to address and mitigate payments fraud across national banks and federal savings associations. The OCC seeks insights on emerging fraud trends, vulnerabilities in payments systems, and effective preventative measures.

On June 13, 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced a civil penalty against GVA Capital, Ltd. for violating U.S. sanctions tied to national security threats. The company was found to have facilitated prohibited transactions involving individuals on the Specially Designated Nationals (SDN) list.

On June 13, 2025, the CFPB proposed rescinding its July 2024 Nonbank Covered Persons Registry Rule—less than a year after its rollout. The proposal would take effect immediately upon Federal Register publication, eliminating the requirement for nonbanks to report prior enforcement or court orders to the CFPB.

On June 4, 2025, the House Financial Services Committee reviewed H.R. 3633, the “Banking Transparency for Sanctioned Persons Act of 2025.” This bill would require the Secretary of the Treasury to issue a report identifying any U.S. financial institution that has knowingly provided services to individuals or entities designated under U.S. sanctions programs, particularly those tied to terrorism, weapons proliferation, or foreign corruption. The intent is to strengthen oversight of the financial sector’s role in sanctions compliance and prevent the misuse of the U.S. financial system by sanctioned persons.

On May 2, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the renewal of existing Geographic Targeting Orders (GTOs) requiring U.S. title insurance companies to report all-cash purchases of residential real estate in designated metropolitan areas.

On May 2, 2025, the Financial Crimes Enforcement Network (FinCEN) released a comprehensive threat analysis detailing patterns and trends in Bank Secrecy Act (BSA) reporting related to the illicit trafficking of fentanyl and fentanyl precursors. The report aims to support financial institutions, law enforcement, and the broader public in understanding how the financial system is exploited by fentanyl traffickers, and to enhance the detection of fentanyl-related illicit finance.

On May 2, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a formal alert warning financial institutions about rising oil smuggling activity along the U.S.-Mexico southwest border. These schemes are being perpetrated by Mexico-based transnational criminal organizations (TCOs) as a means to finance broader illicit operations, including narcotics trafficking and corruption.

On May 1, 2025, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) under Section 311 of the USA PATRIOT Act. The rule designates the Cambodia-based Huione Group as a primary money laundering concern and proposes prohibiting U.S. financial institutions from maintaining correspondent or payable-through accounts for Huione Group.

U.S. Secretary of the Treasury Scott Bessent led a critical public private partnership event in Washington, D.C., focusing on Iran’s access to the global financial system.

The IRS is reminding U.S. taxpayers living and working abroad, including U.S. citizens and resident aliens with dual citizenship, that they must file their 2024 federal income tax return by June 16, 2025.

A federal court in Massachusetts has entered a consent decree requiring SunSetter Products LP to pay $9.25 million in civil penalties and implement a comprehensive compliance program following its failure to timely report a safety defect with retractable awning covers.

OCC has released its Community Reinvestment Act (CRA) performance evaluations for 18 national banks and federal savings associations for the period from March 1, 2025, to March 31, 2025

FinCEN issued an Advisory aimed at assisting financial institutions in identifying and reporting suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS).

SEC has charged three Arizona individuals—Randall “Randy” Miller, Chad Miller, and Jeffrey De Laveaga—over their involvement in defrauding investors in a $284 million municipal bond offering used to finance the construction of a sports complex in Mesa, Arizona

OCC has announced the withdrawal of its participation in the interagency principles for climate-related financial risk management, which were specifically designed for large financial institutions

FinCEN issued an Alert regarding bulk cash smuggling and repatriation schemes involving Mexico-based Transnational Criminal Organizations (TCOs).

The U.S. District Court for the District of Arizona has issued a default judgment against Debiex, a digital asset platform, for fraud in connection with digital asset commodity trading.

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim rule removing the requirement for U.S. companies to report beneficial ownership information under the Corporate Transparency Act (CTA).

OCC on March 17, 2025 announced conditional approval of the application for financial technology (fintech) company SmartBiz Loans to change the business model of CenTrust Bank, N.A., Northbrook, Illinois, upon its acquisition of CenTrust Bank, N.A.

OCC on March 17, 2025, announced conditional approval of the application for financial technology (fintech) company SmartBiz Loans to change the business model of CenTrust Bank, N.A., Northbrook, Illinois, upon its acquisition of CenTrust Bank, N.A.

According to a news dated March 11, 2025, President Donald Trump has announced plans to abolish the CFPB, a move that comes despite the agency’s revival of work on consumer protection issues

Relationship investment scams are a recent type of romance fraud, causing reported losses to the FBI of nearly $4 billion

FinCEN has issued a $37 million civil money penalty against Brink’s Global Services USA, Inc. (Brink’s) for willful violations of the Bank Secrecy Act (BSA). This enforcement action marks FinCEN’s first-ever penalty against an armored car company.

IRS issued a warning to taxpayers to exercise caution when selecting tax preparers to safeguard their personal information. This advisory comes in response to the increasing prevalence of tax-related scams and identity theft during the tax season.

CFPB has issued an enforcement order against Wise US, a major international remittance company, for violating consumer financial protection laws.