AML Conversations De-Banking, FinCEN Alerts, and the Growing Role of State Enforcement
Oct 23, 2026
A sweeping discussion of Russia sanctions, shifting U.S. policy, and the OCC’s controversial de-banking report. The conversation also examines New York’s $33 million action against SEB, alleged concealment of luxury assets, FinCEN alerts involving Iranian charity networks and student aid fraud, FATF’s proposed tiered SAR system, and transparency concerns surrounding a Venezuelan oil deal.
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Russia Policy Creates Sanctions Compliance Uncertainty
- Russia-related sanctions and diplomatic decisions are creating uncertainty for banks’ sanctions compliance and transaction processing.
- Even if sanctions are eased, U.S. banks may not immediately resume Russian activity because operational and regulatory risks remain.
OCC Debanking Report Leaves Banks Whipsawed
- The OCC’s debanking report emphasizes access to services but offers limited statistics and potentially conflicts with institution-specific risk management.
- Elliot Berman says banks should retain documented, risk-based decisions rather than automatically changing policies.
Debanking Rules Could Reach Loan Concentrations
- Access expectations could expand from customer onboarding to individual services, including lending concentrations.
- John Byrne warns that preventing banks from managing industry exposure could weaken the risk-based approach that helped address past crises.