Mar 18
Mar 18 FinCEN Issues GTO Imposing Additional Reporting Requirements Along the Southwest Border

On March 14, 2025, FinCEN issued a notice of a Geographic Targeting Order requiring certain money services businesses along the southwest border of the United States to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions. The order will take effect starting April 14, 2025 and ends on September 9, 2025.

Mar 17
Mar 17 OCC Reaffirms That Certain Crypto-Asset Activities Are Permissible

Adam Witmer

Regulatory Update

On March 7, 2025, the OCC issued a letter to reaffirm that a range of cryptocurrency activities are permissible in the federal banking system. Through Interpretive Letter 1183, the OCC confirmed that crypto-asset custody, certain stablecoin activities, and participation in independent node verification networks such as distributed ledger are permissible for national banks and federal savings associations.

Mar 17
Mar 17 Senate Disapproves CFPB’s Rule to Oversee Digital Payment Apps

Adam Witmer

Regulatory Update

On March 5, 2025, the Senate issued a joint resolution (S.J.Res. 28) disapproving the rule submitted by the CFPB relating to “Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications”. The CFPB finalized the rule in November 2024 which aimed to supervise the largest nonbank companies offering digital funds transfer and payment wallet apps.

Mar 6
Mar 6 CFPB Extends Comment Period for Data Rule

Adam Witmer

Regulatory Update

On 3/5/25, the CFPB published in the Federal Register a proposed rule to extend the comment period from the 12/13/24 notice of proposed ruemaking requesting comment on the CFPB’s proposal to amend Regulation V.

Mar 4
Mar 4 FDIC Delays Portion of Official Sign and Advertising Rule

Adam Witmer

Regulatory Update

On 3/3/25, the FDIC announced that it was postponing the compliance date from May 1, 2025 to March 1, 2026 for the requirements under 12 CFR 328.5 related to the display of the FDIC official digital sign on an insured depository institution’s (IDI’s) digital channels, as well as analogous requirements related to IDI’s automated teller machines (ATMs) and like devices under 12 CFR 328.4.

Mar 4
Mar 4 NCUA to Cease Publication of OD/NSF Fee Data

Adam Witmer

Regulatory Update

On 3/3/25, NCUA Chairman, Kyle S. Haptman, announced that the NCUA “will no longer publish overdraft and non-sufficient fund fee income for individual credit unions.” The NCUA will, however, continue to collect the data during supervisory examinations.

Mar 4
Mar 4 FDIC Withdraws Four Proposed Rules

Adam Witmer

Regulatory Update

On 3/3/25, the FDIC announced that it was withdrawing three proposed rules relating to brokered deposits, corporate governance, and the Change in Bank Control Act (CBCA). The FDIC also announced a withdraw of the authority previously approved by the FDIC Board of Directors to publish a proposed rule on incentive-based compensation arrangements.

Mar 3
Mar 3 FinCEN Announces No Fines for BOI Deadline Violations

Adam Witmer

BSA, Regulatory Update

On 2/27/25, FinCEN announced that it will not impose fines, penalties, or any other enforcement actions against companies that fail to file or update beneficial ownership information (BOI) reports under the Corporate Transparency Act by the current deadlines. In a news release, FinCEN stated that “no fines or penalties will be issued, and no enforcement actions will be taken, until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.”

Feb 28
Feb 28 FinCEN Reminder on Relationship Investment Scams

Adam Witmer

BSA, Regulatory Update

On 2/26/25, FinCEN issued an advisory to remind financial institutions to remain vigilant regarding suspicious activity that may be indicative of relationship investment scams. This alert was issued in support of the multiagency #DatingOrDefrauding Campaign launched by the Commodity Futures Trading Commission to alert the public to relationship investment scams targeting Americans through wrong-numbered texts, dating apps, and social media. The advisory states that losses from romance and confidence scams reported to the Federal Bureau of Investigation exceeded $650 million in 2023.

Feb 27
Feb 27 FATF Updates List of Deficient Countries (2/26/25)

Adam Witmer

BSA, Regulatory Update

On February 26, 2025, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT/CPF deficiencies. In this latest update, the FATF added Laos and Nepal to the list of Jurisdictions Under Increased Monitoring and removed the Philippines. The list of High-Risk Jurisdictions Subject to a Call for Action remains unchanged, with Iran, North Korea (DPRK), and Burma still subject to FATF’s highest level of scrutiny. Specifically, FATF continues to call for countermeasures against Iran and DPRK, while Burma remains subject to enhanced due diligence.