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FinCheck Blog featuring AML Insights and Regulatory Updates
Expert analysis of FinCEN, FATF, and state-level developments, and what they mean for crypto, FinTech, MSB, and gaming businesses.
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123 Red Flags: What the FATF’s New iGaming Paper Means for Online Operators
For seventeen years the FATF's reference point on gambling was a 2009 study of land-based casinos. On 9 September 2026 it published…
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£4.7 Million for 970 Payments: What OFSI’s Citibank Penalty Teaches Every Sanctions Programme
A bank with one of the largest sanctions compliance operations in the world has just been penalised for the unglamorous failures: a…
The Mule Chain Playbook: What the FCA’s Money Mule Review Tells Every Payments Firm
Every fraud has a second act. The scam, the phishing text, the fake investment platform: these get the headlines. But the money…
The Southwest Border GTO Expires Today — and That Is Exactly When MSB Risk Peaks
FinCEN's expanded Geographic Targeting Order ran from 7 March to 2 September 2026. The filing obligation stops. The examination exposure does not.…
The Section 311 Revival: Why FinCEN’s Banque Misr UAE Action Is a FinTech Problem Too
FinCEN issued a notice of proposed rulemaking finding that Banque Misr's operations in the United Arab Emirates are a financial institution of…
Digital Assets Are Now a Sanctionable Sector: OFAC’s Iran Determination and What It Changes
For most of the last decade, sanctions exposure in the digital asset industry was a matching problem. You screened counterparties and wallet…
When ‘Recycled Winnings’ Is Not a Source of Funds: The QuinnBet Settlement and Gaming AML in 2026
The UK Gambling Commission announced that QuinnBet (Gibraltar) Limited will pay £609,104 to settle an enforcement case covering anti-money laundering and social…
97% of the Filings, 3% of the Dollars: What FinCEN’s Human Smuggling Analysis Reveals About Your Detection Model
FinCEN published a Financial Trend Analysis that belongs on every BSA officer's desk this week. Across 67,540 Bank Secrecy Act reports filed…
Recidivism Is the New Red Flag: What FinCEN’s Historic $125M UBS Penalty Means for Every AML Program
FinCEN assessed a $125 million civil money penalty against UBS Financial Services Inc. — the largest BSA penalty ever imposed on a…
The CTA Rollback Is Final: FinCEN Ends Beneficial Ownership Reporting — and Shifts the Burden Back to You
FinCEN issued a final rule that permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI)…
Stablecoin Compliance Gets Real: What the FinCEN–OFAC GENIUS Act Proposal Means for Issuers — and Everyone Who Touches Their Coins
For years, stablecoin issuers operated in a gray zone: registered as money services businesses, screening against OFAC lists as a best practice,…
The Crypto ATM Reckoning: Indiana’s Ban, Wisconsin’s Blueprint, and the New State Compliance Baseline for Kiosk Operators
The numbers finally caught up with the machines. In 2025, the FBI's Internet Crime Complaint Center logged more than 13,400 complaints tied…
Sanctioned, Renamed, Back in Business: What FinCEN’s “Successor Entity” Move Against H-Pay Means for Your Screening Program
FinCEN did something it rarely does: it used its most powerful tool — a special measure under Section 311 of the USA…
Payroll Fraud Meets AML: What FinCEN’s New Advisory (FIN-2026-A002) Means for MSBs, Payroll Firms, and FinTechs
FinCEN — jointly with the FDIC, OCC, and NCUA and in coordination with the IRS — issued Advisory FIN-2026-A002, targeting illicit finance…
The Post-MiCA Era Begins: What the July 1 CASP Deadline and AMLA’s Ramp-Up Mean for Global Crypto Compliance
The era of transitional tolerance for crypto-asset service providers (CASPs) in the European Union officially ended. The grandfathering window under the Markets…
Whose Compliance Program Is It, Anyway? Sponsor Banks, FinTechs, and the New AML Accountability in BaaS
For a decade, Banking-as-a-Service ran on a comfortable fiction: the sponsor bank “owned” BSA/AML compliance, and the FinTech simply rode on its…
Stablecoins Have Become Crime’s Favorite Rail: Inside FATF’s Seventh Virtual-Asset Review
The Financial Action Task Force published its Seventh Targeted Update on the implementation of its standards for virtual assets and virtual asset…
The Perimeter Just Moved: Maine’s Sweepstakes Ban Is Live — and Payment Processors Are Now in the Line of Fire
Maine’s LD 2007 took effect, prohibiting online sweepstakes games built on dual-currency systems and casino-style simulations. Two weeks earlier, on July 1,…
From Paperwork to Performance: FinCEN’s AML Program Overhaul and the 12-Month Runway Ahead
The most consequential rewrite of U.S. AML program rules in a generation is now moving toward the finish line. FinCEN's proposed rule…
Reading the National Threat Map: What Treasury’s 2026 Money Laundering Risk Assessment Means for Your Program
Every few years, the U.S. Department of the Treasury pulls back the curtain and tells the private sector where the money is…
Chinese Money Laundering Networks: The Cartel Laundering Threat on America’s Doorstep
FinCEN named a threat that had been hiding in plain sight inside the U.S. financial system: Chinese Money Laundering Networks (CMLNs). Nearly…
Drawing the Line: Why Geolocation Integrity Became a Core AML Control in 2026 Gaming
A player’s location used to be a product question. In 2026, it is a money-laundering question. For most of the last decade,…
When Payroll Becomes a Laundering Channel: Inside FinCEN’s New Advisory on Off-the-Books Wage Schemes
In 2025, U.S. financial institutions filed more than $2.5 billion in suspicious activity tied to a single, often-overlooked typology: payroll tax fraud.…
Stablecoins Enter the BSA Era: What FinCEN and OFAC’s GENIUS Act Rule Means for Issuers
For years, stablecoin issuers operated in a regulatory grey zone — treated, if at all, as money transmitters under a money services…
ACH Fraud Monitoring Becomes Mandatory for Everyone: Inside NACHA’s Phase 2 Rule
The last safe harbor disappears. NACHA's credit-push fraud monitoring rule enters Phase 2, and the volume threshold that shielded smaller players in…
The AML Program Rulebook Is Being Rewritten: Inside FinCEN’s “Effective and Reasonably Designed” Standard
The comment window closes on June 9, 2026 — and with it, the industry’s best chance to shape the most consequential rewrite…
Deepfake KYC Attacks: Defending Customer Onboarding Against AI-Powered Identity Fraud
The Identity Layer Is Cracking Three years ago, a forged driver’s license and a stolen Social Security number were the gold standard…
Real Estate AML in Limbo: Navigating FinCEN’s Vacated Rule and the Fifth Circuit Appeal
Eighteen days. That is how long the U.S. Treasury’s signature anti-money-laundering rule for the residential real estate sector survived after taking…
Red Flags Before Kickoff: FinCEN’s FIFA World Cup Human Trafficking Notice and the 5-Week Sprint Ahead
A FinCheck LLC perspective on operationalizing FIN-2026-HTWORLDCUP across MSBs, FinTechs, gaming platforms, and BaaS sponsors before June 11, 2026. On May 11,…
Beyond the SDN List: Operationalizing FinCEN’s May 2026 IRGC Alert in Your AML Program
The Financial Crimes Enforcement Network (FinCEN) issued one of the most operationally consequential alerts of the year. Aimed squarely at U.S. financial…
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 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,…
The Sweepstakes Casino Reckoning: How the 2026 State Ban Wave Is Reshaping AML & Compliance for the Entire Vendor Stack
Three more U.S. states — Oklahoma, Tennessee, and Louisiana — edged within striking distance of final votes on bills that would criminalize…
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…
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…
276 Arrests, Nine Scam Centers Down: What the Global Pig-Butchering Crackdown Means for FinTechs, MSBs and Crypto Firms
An international task force led by Dubai Police, with the FBI, China's Ministry of Public Security and Thai authorities, arrested 276 suspects…
Black Axe in Zurich: Romance Scams, Mule Networks, and the AML Blind Spots Every Financial Institution Must Close
Swiss authorities — supported by Europol and German federal police — executed coordinated raids across Zurich and five additional cantons, arresting ten…
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…
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…
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…
Fraud–AML Convergence: Why Siloed Financial Crime Programs Are Breaking in 2026
Regulators, criminals, and boards are all pushing the same message — it is time to tear down the walls between fraud and…
Correspondent Banking De-Risking in 2026: Why MSBs and FinTechs Are Being Shut Out — and Five Moves to Preserve Banking Relationships
Last quarter, three Money Service Businesses I advise received nearly identical letters: "After a comprehensive review of your account, we are unable…
The GENIUS Act Meets the BSA: What the New Stablecoin AML and Sanctions Rules Mean for Compliance Teams
The U.S. Department of the Treasury dropped what many in the compliance community have been anticipating for months: a joint proposed rule…
From Rule Books to Reasoning Machines: How Agentic AI Is Redefining AML Transaction Monitoring in 2026
There is a crisis hiding in plain sight inside most financial institutions' compliance operations. It has nothing to do with money launderers…
EU AMLA Is Live: Europe’s New AML Watchdog and What It Means for Your Business
The European Anti-Money Laundering Authority (AMLA) held its first public hearing — a moment that marked more than a bureaucratic milestone. It…
iGaming & Sweepstakes in the USA: The Rising AML & Financial Crime Frontier
The United States iGaming and sweepstakes industry has experienced explosive growth over the past several years, attracting millions of players to online…
The Biggest AML Reform in a Generation: What FinCEN’s Proposed Rule Means for Your Compliance Programme
United States financial regulators took a step that compliance professionals have been anticipating — and debating — for years. FinCEN, together with…
KYC Compliance Services: What Every FinTech Startup Needs to Know Before You Scale
For a FinTech startup, the path from product launch to regulated operations can feel like navigating a maze with the lights off.…
How to Register as an MSB with FinCEN: A Step-by-Step Compliance Guide
If you're building a FinTech company, launching a crypto exchange, or operating a payment processing platform in the United States, FinCEN…
Crypto AML Regulations in the United States
The cryptocurrency industry in the United States has moved from experimental technology to mainstream financial infrastructure. Billions of dollars flow through crypto…
Money Transmitter License in USA – Complete Guide
Money Transmitter License in USA: Complete Compliance Guide for 2026 Getting a money transmitter license in the USA isn't just a regulatory…
What is AML Compliance and Why It Matters for FinTech
The FinTech revolution has transformed how billions of people access financial services. But this innovation comes with a sobering responsibility: preventing your…
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