Payroll Fraud Meets AML: What FinCEN’s New Advisory (FIN-2026-A002) Means for MSBs, Payroll Firms, and FinTechs
On June 5, 2026, FinCEN — jointly with the FDIC, OCC, and NCUA and in coordination with the IRS — issued Advisory FIN-2026-A002, targeting illicit finance tied to unlawful employment and payroll fraud. On the surface, this looks like an employment and tax enforcement issue. Read it closely, and it is one of the most […]
The Post-MiCA Era Begins: What the July 1 CASP Deadline and AMLA’s Ramp-Up Mean for Global Crypto Compliance
On July 1, 2026, the era of transitional tolerance for crypto-asset service providers (CASPs) in the European Union officially ended. The grandfathering window under the Markets in Crypto-Assets Regulation (MiCA) closed, meaning any firm serving EU customers without full MiCA authorization is now operating illegally. At the same time, the EU’s new Anti-Money Laundering Authority […]
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 charter. That fiction is now officially dead. Between the April 2026 joint AML program proposal from the FDIC, NCUA, and OCC, FinCEN’s parallel rulemaking under the AML Act of 2020, and a steady […]
Stablecoins Have Become Crime’s Favorite Rail: Inside FATF’s Seventh Virtual-Asset Review
On July 16, the Financial Action Task Force published its Seventh Targeted Update on the implementation of its standards for virtual assets and virtual asset service providers — and the headline is blunt: organised crime groups are moving billions of dollars in illicit proceeds through the crypto sector by exploiting the gaps between jurisdictions that […]
The Perimeter Just Moved: Maine’s Sweepstakes Ban Is Live — and Payment Processors Are Now in the Line of Fire
Yesterday, July 14, 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, Indiana’s HB 1052 did the same, establishing civil penalties for conducting a sweepstakes game in the state. With Connecticut, Montana, New Jersey, California, and New York having acted in 2025, […]
From Paperwork to Performance: FinCEN’s AML Program Overhaul and the 12-Month Runway Ahead
By Syed Khalid, CEO & Fractional Chief Compliance Officer, FinCheck LLC · July 13, 2026 The most consequential rewrite of U.S. AML program rules in a generation is now moving toward the finish line. FinCEN’s proposed rule to reform anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements — published in April 2026 […]
Reading the National Threat Map: What Treasury’s 2026 Money Laundering Risk Assessment Means for Your Program
By Syed Khalid, CEO & Fractional Chief Compliance Officer, FinCheck LLC · July 1, 2026 Every few years, the U.S. Department of the Treasury pulls back the curtain and tells the private sector where the money is actually moving. Its 2026 National Money Laundering Risk Assessment (NMLRA), released alongside companion assessments on terrorist financing and […]
Chinese Money Laundering Networks: The Cartel Laundering Threat on America’s Doorstep
In August 2025, FinCEN named a threat that had been hiding in plain sight inside the U.S. financial system: Chinese Money Laundering Networks (CMLNs). Nearly a year later, the warning has only grown louder. Treasury’s 2026 National Money Laundering Risk Assessment now calls these networks the dominant professional money-laundering service for drug cartels worldwide, a […]
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, geolocation in online gaming was treated as a user-experience feature — a quiet gatekeeper that decided whether an app would load in a given state. The 2026 wave of state enforcement against unlicensed […]
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. On June 5, 2026, FinCEN responded. Its new interagency advisory, FIN-2026-A002, asks banks, money services businesses, and fintech platforms to treat off-the-books payroll arrangements as what they increasingly are — a structured, shell-company-driven […]