About the Course
Introduction
This CLE webinar will discuss the latest developments in regulatory scrutiny and enforcement against banks, financial institutions, and their boards of directors under the Bank Secrecy Act (BSA), Anti-Money Laundering (AML), and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). The panel will explore lessons learned from recent regulatory enforcement actions and provide best practices for advising clients on BSA/AML/OFAC compliance under the evolving legal and regulatory framework.
Description
BSA/AML and OFAC concerns continue to drive a significant portion of agency enforcement efforts, and the current regulatory environment has been shaped by notable developments in BSA, AML, and OFAC compliance, making this a dynamic area to monitor for financial institutions. Also, recent institution compliance failures and record-breaking civil and criminal monetary penalties highlight trends and lessons for BSA/AML and OFAC compliance programs going forward.
Two recent developments may indicate a changing regulatory approach to BSA/AML and OFAC compliance. First, on Oct. 9, 2025, FinCEN and federal banking regulators issued joint guidance in the form of FAQs regarding Suspicious Activity Reports (SARs). The FAQs clarified both the legal standards and practical expectations within the SAR regulatory scheme. Second, on Oct. 21, 2025, Senate Republicans introduced a new bill titled Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (STREAMLINE Act). This bill would increase the threshold amounts applicable to certain currency transaction reports and SAR reports under the BSA.
The stakes are high for financial institutions, boards of directors, and senior management, and recent enforcement activity provides counsel with a road map of regulators' expectations. Counsel to financial institutions must assess BSA/AML and OFAC risks and current BSA/AML/OFAC programs to minimize potential noncompliance.
Listen as our authoritative panel analyzes the latest regulatory enforcement actions and developments regarding BSA/AML and OFAC compliance and provides best practices for assessing the effectiveness of clients' BSA/AML and OFAC programs.
Presented By
Mr. Stipano provides assistance in establishing, maintaining and monitoring anti-money laundering/countering the financing of terrorism (AML/CFT) compliance programs, conducts investigations and represents clients in regulatory matters, including state and federal regulatory enforcement actions. His regulatory and enforcement experience includes more than 30 years at the Office of the Comptroller of the Currency (OCC). As Deputy Chief Counsel from 2000 to 2016, Mr. Stipano played a key role in significant Bank Secrecy Act (BSA) rulemakings and policy issuances and oversaw major OCC enforcement actions. Prior to that, he served as the Director of Enforcement. Mr. Stipano has testified six times before Congress on enforcement and AML/CFT matters. He is a member of the advisory boards of ACAMS and the ABA/ABA Financial Crimes Enforcement Conference.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Wednesday, February 25, 2026
- schedule
1:00 PM E.T.
I. Overview: BSA/AML and OFAC compliance parameters
II. Recent enforcement actions and regulatory scrutiny
III. FinCEN's and banking regulators' joint guidance regarding SARs
IV. STREAMLINE Act
V. Defenses for enforcement actions and effective remediation efforts
VI. Best practices for assessing BSA/AML and OFAC compliance programs
VII. Practitioner pointers and key takeaways
The panel will review these and other key issues:
- What are the key lessons from recent regulatory enforcement actions concerning BSA/AML and OFAC violations?
- What corrective actions and remediation efforts are regulators requiring in the wake of bank examinations where inadequate compliance programs are identified?
- What are the critical components of effective risk-based compliance and monitoring programs?
- How does the recent joint guidance from FinCEN and federal regulators on SARs and the proposed STREAMLINE Act signal a potential shift in BSA/AML reporting in the future?
