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FinCEN’s Proposed AML/CFT Program Reform: What Financial Institutions and Auditors Need to Know
In April 2026, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that would fundamentally reshape how financial institutions design, implement, and are examined on their anti-money laundering and countering the financing of terrorism (AML/CFT) programs. If finalized, this proposal represents the most significant rethink of Bank Secrecy Act (BSA) compliance in decades, particularly in how program effectiveness is evaluated. For ban
The Bankers Solutions
ISO20022 vs. The Travel Rule... Which Applies?
The ISO requirements were not intended to, and should never supersede the requirement for the Travel Rule. The banks’ default decision should be to abide by the law.
The Bankers Solutions
HMDA Tips Community Banks Should Not Overlook
HMDA reporting continues to be a common source of examination findings, especially when loan types and data requirements are misunderstood. Key areas to watch include: Commercial Loans - Many HMDA reportable loans at community banks are commercial purpose loans secured by dwellings. Several data fields must be reported as “NA” rather than left blank. Understanding which fields apply is critical. Documentation - Every one of the 110 HMDA data fields should be supported by cons
The Bankers Solutions
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FinCEN’s Proposed AML/CFT Program Reform: What Financial Institutions and Auditors Need to Know
In April 2026, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that would fundamentally reshape how financial institutions design, implement, and are examined on their anti-money laundering and countering the financing of terrorism (AML/CFT) programs. If finalized, this proposal represents the most significant rethink of Bank Secrecy Act (BSA) compliance in decades, particularly in how program effectiveness is evaluated. For ban
Apr 22
ISO20022 vs. The Travel Rule... Which Applies?
The ISO requirements were not intended to, and should never supersede the requirement for the Travel Rule. The banks’ default decision should be to abide by the law.
Feb 19
HMDA Tips Community Banks Should Not Overlook
HMDA reporting continues to be a common source of examination findings, especially when loan types and data requirements are misunderstood. Key areas to watch include: Commercial Loans - Many HMDA reportable loans at community banks are commercial purpose loans secured by dwellings. Several data fields must be reported as “NA” rather than left blank. Understanding which fields apply is critical. Documentation - Every one of the 110 HMDA data fields should be supported by cons
Jan 12
Third Party Risk Management Remains an Examination Priority
Third party relationships continue to receive increased scrutiny from regulators, particularly as banks rely more heavily on FinTech's, core providers, and outsourced compliance services. Examiners are looking beyond contracts to evaluate: Vendor due diligence and ongoing monitoring Risk tiering and supporting documentation for the risk tier chosen Board oversight of critical vendors Alignment between vendor risk and internal controls Are your vendors using AI and are you ask
Jan 12
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