All in BSA

On March 31, 2026, the OFAC issued a sanctions advisory to highlight sanctions risks arising from sham transactions used to evade sanctions and to identify factors to consider when evaluating whether property may be the subject of a sham transaction. Sham transactions occur when blocked individuals use intermediaries to falsely give up property to evade sanctions while still retaining an interest in it.

On March 30, 2026, FinCEN issued an Advisory to urge financial institutions to be vigilant in identifying and reporting suspicious transactions potentially related to health care fraud schemes targeting Medicare, Medicaid, and other Federal and state health care benefit programs. The Advisory builds on Treasury’s work to combat the potentially billions of dollars in rampant health care and government benefits fraud in Minnesota and across the country.

On March 30, 2026, FinCEN issued a proposed rule to fully implement a whistleblower program by establishing a framework for offering incentives and protections to encourage individuals to report tips on fraud-related violations of the Bank Secrecy Act, U.S. sanctions programs administered by Treasury’s OFAC, and several other laws critical to safeguarding the U.S. financial system and national security. The proposed rule would implement section 6314 of the Anti-Money Laundering Act of 2020 and the Anti-Money Laundering Whistleblower Improvement Act.

VIDEO: SAR Timelines for Continuing Activity

In this Compliance Clip (video), Adam explores a key BSA/AML question that many financial institutions face: how to handle the timeline when suspicious activity continues after an initial SAR filing. Drawing on longstanding guidance and more recent clarification, Adam walks through how institutions should think about timing and the practical challenges that can arise. If you've ever wondered how the continuing activity timeline actually works in practice, this quick overview will point you in the right direction. A transcript of this video is now available.

On March 12, 2026, OFAC sanctioned six individuals and two entities for their roles in Democratic People’s Republic of Korea (DPRK) government-orchestrated information technology (IT) worker schemes that systematically defraud U.S. businesses. According to the OFAC, the scheme generates revenue to fund the DPRK’s weapons of mass destruction (WMD) programs, including nearly $800 million in 2024.

On March 6, 2026, FinCEN assessed an $80,000,000 civil money penalty against Canaccord Genuity LLC for willful violations of the Bank Secrecy Act and its implementing regulations. Canaccord is a broker-dealer headquartered in New York that provides market-making and trade execution services in securities primarily for institutional clients such as money managers, hedge funds, and financial institutions.

On February 26, 2026, FinCEN issued a proposed rule that, if finalized, would sever MBaer Merchant Bank AG (MBaer’s) access to the U.S. financial system as a result of its financial support to illicit actors linked to Russia and Iran.  If finalized, the proposed rule would prohibit covered U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, MBaer.