ACH Fraud Monitoring Becomes Mandatory for Everyone: Inside NACHA’s Phase 2 Rule
On Monday, June 22, 2026, the last safe harbor disappears. NACHA’s credit-push fraud monitoring rule enters Phase 2, and the volume threshold that shielded smaller players in Phase 1 is gone. Every non-consumer Originator, Third-Party Sender, Third-Party Service Provider, and every Receiving Depository Financial Institution — regardless of how many ACH entries they move — […]
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 business (MSB) framework that was never designed for tokens that move value on public blockchains. That ambiguity is ending. On April 8, 2026, FinCEN and OFAC jointly issued a Notice of Proposed Rulemaking […]
ACH Fraud Monitoring Becomes Mandatory for Everyone: Inside NACHA’s Phase 2 Rule
On Monday, June 22, 2026, the last safe harbor disappears. NACHA’s credit-push fraud monitoring rule enters Phase 2, and the volume threshold that shielded smaller players in Phase 1 is gone. Every non-consumer Originator, Third-Party Sender, Third-Party Service Provider, and every Receiving Depository Financial Institution — regardless of how many ACH entries they move — […]
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 of U.S. anti-money laundering program rules in a generation. On April 7, FinCEN issued a proposed rule that would fundamentally reform the AML/CFT program requirements sitting at the heart of every Bank Secrecy […]
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 of identity fraud. In 2026, a laptop, fifteen seconds of social-media audio, and an open-source face-swap model can produce a synthetic customer that passes video selfie checks, liveness prompts, and document-authentication scans — […]
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 effect. The Residential Real Estate Reporting Rule went live on March 1, 2026 — the culmination of a decade-in-the-making expansion of the Bank Secrecy Act into title companies, settlement agents, and closing attorneys. […]
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, 2026 — exactly one month before kickoff — FinCEN issued a Notice (FIN-2026-HTWORLDCUP) urging financial institutions to elevate their vigilance for human trafficking activity tied to the 2026 FIFA World Cup. With 104 […]
Beyond the SDN List: Operationalizing FinCEN’s May 2026 IRGC Alert in Your AML Program
On May 11, 2026, the Financial Crimes Enforcement Network (FinCEN) issued one of the most operationally consequential alerts of the year. Aimed squarely at U.S. financial institutions, the Alert dissects how Iran’s Islamic Revolutionary Guard Corps (IRGC) moves the proceeds of illicit oil sales through shell companies, exchange-house networks, and — increasingly — stablecoins. For […]
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 […]