BSA/AML Priorities Under a New Administration

18 snips

Jan 15, 2026

Terence Grugan, co-chair of Ballard Spahr's AML team, dives into the evolving landscape of anti-money laundering compliance. He discusses recent regulatory streamlining efforts aimed at easing burdens on financial institutions. Terence highlights the emphasis on targeted examinations for community banks and emerging trends in non-bank entities under FinCEN. He also clarifies new SAR reporting guidance and the implications of the GENIUS Act for stablecoins, shedding light on compliance adaptations in the rapidly changing financial world.

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INSIGHT

Treasury Prioritizes Deregulation Over Expansion

The Treasury is prioritizing economic growth and deregulation in AML policy under the new administration.
This shift focuses AML on efficiency and reducing burdens rather than expanding scope aggressively.

INSIGHT

Big Expansion Rules Have Been Rolled Back

Major expansion efforts like the Corporate Transparency Act and new BSA rules for investment advisors have been scaled back or delayed.
FinCEN limited CTA enforcement and pushed the investment advisor rule's effective date to 2028 for reassessment.

ADVICE

Use FinCEN SAR Clarifications To Cut Burden

Rely on clarified FinCEN SAR guidance to reduce unnecessary filings and documentation.
Stop over-documenting non-filings and focus SARs on real suspicions like structuring plus corroborating factors.

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Join us for a timely and insightful conversation on the evolving landscape of anti-money laundering (AML) compliance in consumer financial services. In this episode of the Consumer Finance Monitor Podcast, Alan Kaplinsky, founder and senior counsel of Ballard Spahr's Consumer Financial Services Group, hosts Terence Grugan, co-chair of Ballard Spahr's AML team and a recognized authority in financial crimes compliance. Together, they deliver a comprehensive discussion on the latest regulatory developments, enforcement trends, and strategic implications for institutions across the industry.

Episode Overview and Key Takeaways:

1. Regulatory Streamlining: Explore how AML and Bank Secrecy Act (BSA) compliance requirements are being recalibrated, with a focus on reducing unnecessary burdens, modernizing supervisory practices, and emphasizing substance over form.

2. Bank Examination Modernization: Learn how recent policy changes are promoting risk-based, targeted examinations for community banks, enabling institutions to allocate resources more effectively while maintaining compliance.

3. Non-Bank Financial Institution Developments: Gain insights into emerging proposals from FinCEN and the Treasury aimed at gathering industry feedback and potentially scaling back AML obligations for non-bank entities such as casinos, money services businesses, and others.

4. SAR Reporting Reforms: Hear about FinCEN's clarifications that are refining suspicious activity reporting (SAR) requirements, streamlining documentation, and reducing operational complexity for financial institutions.

5. Evolving Crypto Regulation: Assess the regulatory retreat within the cryptocurrency sector, implications for AML risk, and anticipated impact of new regulatory initiatives including upcoming Stablecoin rules.

6. Enforcement Trends: Review notable shifts in enforcement priorities, with fewer high-profile AML fines this year and an increased focus on targeting substantive violations rather than technical compliance failures.

7. National Security and Economic Policy Alignment: Understand how AML and financial crime policies are aligning with broader national security priorities, including sanctions compliance, immigration enforcement, and efforts to disrupt international cartels.

8. Future Outlook: Preview possible future developments, including greater centralization of AML enforcement within the Treasury Department and continuing modernization of compliance obligations.

This episode equips financial institutions, compliance professionals, and industry leaders with expert perspectives on the regulatory, operational, and strategic changes transforming AML compliance.

Consumer Finance Monitor is hosted by Alan Kaplinsky, Senior Counsel at Ballard Spahr, and the founder and former chair of the firm's Consumer Financial Services Group. We encourage listeners to subscribe to the podcast on their preferred platform for weekly insights into developments in the consumer finance industry.