The Travel Rule at Five: Why Most VASPs Still Fail FATF Recommendation 16 in 2026
Five years after the Financial Action Task Force pushed Recommendation 16 — the so-called Travel Rule — into the virtual asset world, the gap between the rule on paper and the rule in practice is still embarrassing. In 2026, the global crypto economy moves trillions of dollars in value every quarter, yet a meaningful share […]
The Independent AML Audit in 2026: Top Findings Regulators Are Citing — and How to Fix Them Before They Become Consent Orders
Every quarter, my team and I close out a fresh batch of independent AML audits across FinTechs, money service businesses, crypto platforms, sweepstakes and social-gaming operators, payroll processors, and BaaS clients. The faces and product stacks change. The findings, increasingly, do not. In 2026, federal and state examiners are no longer rewarding good intentions or […]
The Sweepstakes Casino Reckoning: How the 2026 State Ban Wave Is Reshaping AML & Compliance for the Entire Vendor Stack
On May 6, 2026, three more U.S. states — Oklahoma, Tennessee, and Louisiana — edged within striking distance of final votes on bills that would criminalize the sweepstakes-casino business model. They join California, which under AB 831 made operating a sweepstakes casino a misdemeanor and, critically, extended liability to every vendor in the value chain: […]
The PEP Paradox: Why Politically Exposed Persons Screening Is Quietly Failing — and How to Rebuild It in 2026
Two decades after the Financial Action Task Force introduced Politically Exposed Persons (PEP) requirements, screening for political risk should be one of the most mature controls in any AML program. Instead, in 2026 it has quietly become one of the weakest. Enforcement actions on three continents in the past six months reveal a familiar pattern: […]
Sponsor Bank Reckoning: Why BaaS FinTech Partnerships Need an AML Reset in 2026
The era of treating Banking-as-a-Service (BaaS) as outsourced compliance is officially over. After the Synapse collapse, a wave of FDIC consent orders against sponsor banks, and FinCEN’s April 2026 proposal to overhaul the entire AML program rulebook, U.S. regulators have made one thing unambiguous: every dollar that flows through a sponsor bank charter is the […]
276 Arrests, Nine Scam Centers Down: What the Global Pig-Butchering Crackdown Means for FinTechs, MSBs and Crypto Firms
In late April 2026, an international task force led by Dubai Police, with the FBI, China’s Ministry of Public Security and Thai authorities, arrested 276 suspects and shut down at least nine cryptocurrency “pig-butchering” scam centres. The U.S. DOJ followed days later by seizing roughly USD 61 million tied to a single North Carolina cluster […]
Black Axe in Zurich: Romance Scams, Mule Networks, and the AML Blind Spots Every Financial Institution Must Close
On April 28, 2026, Swiss authorities — supported by Europol and German federal police — executed coordinated raids across Zurich and five additional cantons, arresting ten suspected members of the Nigerian-origin Black Axe organisation. The charges cover romance scams, multi-million Swiss-franc cyber fraud, and serious money laundering. It is the second European strike against the […]
Southwest Border GTO 2026: Inside FinCEN’s Expanded MSB Reporting Net
Why this matters right now On March 10, 2026, FinCEN renewed and significantly expanded the Southwest Border Geographic Targeting Order, lowering the cash-transaction reporting threshold to $1,000 for covered money services businesses across designated counties in California, Texas, New Mexico, and Arizona. The order took effect on March 7 and runs through September 2, 2026. […]
When Stablecoins Count as Tangible Net Worth — What the New CSBS MTMA Guidance Means for Money Transmitters
While federal lawmakers debate the GENIUS Act and Washington writes the rulebook for payment stablecoins, something quieter — and in many ways more operationally consequential — just happened at the state level. On April 2, 2026, the Conference of State Bank Supervisors (CSBS) updated its Money Transmission Modernization Act (MTMA) Implementation Guidance, issuing interpretive direction […]
When ACH Meets Stablecoins: The New AML Frontier at the On- and Off-Ramp
Reading NACHA’s 2026 White Paper Through a Financial Crime Lens — and What Banks, Wallet Providers, and Stablecoin Issuers Must Do Next Stablecoins are no longer a crypto-native curiosity. They are becoming tokenised money — and the rails that fund and redeem them are the same rails our AML programs have been governing for five […]