Insights

In our client alert of September 30, 2026,1 we provided an executive summary of federal banking regulators’ Proposed Third-Party Risk Management Guidance (the “Proposal”), a related joint statement on community banks’ engagement with core service providers, and a proposed Federal Reserve guide for traditional community banks (the “Community Bank Guide”).2 This blog post covers what these agency pronouncements mean for fintechs and the banks that sponsor their programs.

Key Takeaways:

On September 2, 2026, the Federal Reserve, FDIC, NCUA, OCC, and FinCEN confirmed that a bank may tell a customer that an account restriction or closure, or a rejected deposit, may be related to suspected fraud or other suspicious activity, so long as the communication does not reveal that a SAR was or will be filed.

Key Takeaway: Domestic reporting companies—meaning entities formed under the laws of any U.S. state or Tribal jurisdiction—have no beneficial ownership information reporting obligations to FinCEN under the final rule.

Key takeaway #1: On August 13, 2026, FinCEN issued a Financial Trend Analysis showing 67,540 Bank Secrecy Act (BSA) reports filed between 2023 and 2025 involved more than $4.9 billion in reported suspicious activity potentially related to human smuggling. 

The deadline to file OFAC’s Annual Report of Blocked Property (“ARBP”) is approaching fast.  All “U.S. persons” — including U.S. financial institutions, companies, and individuals — who hold property blocked pursuant to any OFAC sanctions program should take a moment to assess their reporting obligations, as set forth in 31 C.F.R. § 501.603.