Two recent guilty pleas by former TD Bank employees — Oscar Marcel Nunez-Flores and Wilfredo Aquino — are a timely reminder that insider-enabled money laundering can defeat control frameworks if banks do not actively design for, detect, and deter employee misconduct. These cases come on the heels of TD Bank’s October 2024 criminal guilty plea
Speaking at the Clearing House’s annual conference, Comptroller of the Currency Jonathan Gould assured industry leaders that the agency remains steadfast in defending federal preemption under the National Bank Act. Gould’s comments come in the wake of recent federal appellate court decisions in the Ninth and First circuits, which challenged the OCC’s stance by finding
Two recent developments signal that momentum is building in Washington to recalibrate Bank Secrecy Act (BSA) reporting to produce higher‑value intelligence with less compliance friction. First, on October 9, 2025, the Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators issued joint guidance in the form of Suspicious Activity Report (SAR) FAQs clarifying several
In its 2024 decision Cantero v. Bank v. America, N.A., the Supreme Court established the approach courts must follow in determining whether a state consumer financial law prevents or significantly interferes with the exercise of a national bank’s powers and is, therefore, preempted by the National Bank Act. In doing so, the Supreme Court
On September 8, 2025, the Office of the Comptroller of the Currency (OCC) released Bulletin 2025-22, announcing that the OCC will assess an entity’s debanking practices when considering licensing filings and applications and during Community Reinvestment Act (CRA) assessments. National banks and federal savings associations are now on notice that prior allegations of politicized
Late last year, we predicted that the Trump administration would bring federal action to target de-banking, and on August 7, 2025, President Trump signed a much-anticipated executive order to address the issue. Banks and credit unions should now expect to feel the impact early on in the form of horizontal reviews and inquiries from their
Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises flexibility for banks and fintech companies. The exemption allows certain financial institutions to collect a taxpayer identification number (TIN) from a reliable third-party source
Starting July 1, 2025, Idaho will subject financial institutions with total assets over a certain threshold to new restrictions under the Transparency in Financial Services Act. The law follows a growing trend among states seeking to ensure fair access to banking and prevent financial denials based on political, religious, or ideological factors — often known
On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The GTO significantly lowers the Currency Transaction Reports (CTR) threshold from $10,000 to $200 for money service businesses (MSBs) operating in 30 zip codes across
On December 12, 2024, the Consumer Financial Protection Bureau (CFPB) announced its final rule, redefining overdraft fees as finance charges in order to limit overdraft fees. The final rule seeks to regulate how overdraft fees are charged and collected in an effort to save consumers money. The CFPB believes the new rule will save