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AML/CFT Policy and Procedure Checkup
FinCEN continues to make communication updates. This is a reminder to check your AML/CFT policies and procedures to make sure they contain the following recently updated contact information: TCA – A Better Way!
Turning Downtime Into Uptime: Using Regulatory Lulls to Fortify Compliance
The Critical Role of Compliance Management System Risk Assessment We are all familiar with the emphasis placed on meaningful risk assessments throughout our industry. Among the many risk assessments that should be created for banks, the Compliance Management Systems Risk Assessment (CMSRA) is perhaps the most important. The importance of a thorough Risk Assessment cannot […]
FinCEN Updates Compliance Date for New Type of Special Measure
This is an update of our June 27,. 2025 article with updated dates. TCA – A Better Way!
Regulatory Updates – Second Quarter 2025
Below is a link to the Regulatory Updates as of the end of Q2 2025. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. TCA – A Better Way!
Executive Order on Disparate impact and What a Bank Should Know
On April 23, 2025, an Executive Order regarding Disparate Impact was issued. The Order states: “It is the policy of the United States to eliminate the use of disparate-impact liability in all contexts to the maximum degree possible.” In addition, it requires the assessment of pending investigations and litigation to extend to the Department of […]
FinCEN Issues New Type of Special Measure
As part of a supplemental appropriations bill passed in September 2024, Congress enacted the FEND Off Fentanyl Act. Section 2313(a) granted the U.S. Treasury the authority to impose special measures against financial institutions suspected of funneling illegal proceeds derived from the illegal manufacture, transportation, and sale of fentanyl. TCA – A Better Way!
Focus on Fraud and Suspicious Activity Reporting
A big focus of conversations in the AML/CFT world recently has focused on the increase in fraud schemes as a mechanism to generate illicit funds which are then ultimately laundered. Financial institutions of all sizes are feeling the impact of fraud schemes targeting their customers and their bottom lines. TCA – A Better Way!
What should AML Programs Learn from Consent Orders?
AML/CFT Consent Orders…AML/CFT Regulatory Fines. These are two phrases that compliance professionals all hear, and hope will never apply to their financial institutions. Yet these actions do occur frequently enough to make one wonder -what steps might be taken to avoid them? TCA – A Better Way!
Dodd Frank Section 1071 Small Business Data Collection Rule Postponed
On June 18, 2025, the CFPB published an interim final rule effective on July 18, 2025, postponing the effective date of Regulation B implementation of the Section 1071 Small Business Data Collection Rule. The summary states: In light of court orders in ongoing litigation, the Consumer Financial Protection Bureau (CFPB or Bureau) is amending Regulation […]
FinCEN Advisories and Key Terms When Filing SARs
FinCEN issues public and non-public advisories to financial institutions in order to help educate them in detecting, preventing, and reporting potential suspicious activity to FinCEN. TCA – A Better Way!
