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Your RIA May Now Be Legally Required to Have an AML Program. Here's What That Means.
FinCEN & RegulationEffective Jan 1, 2026Featured

Your RIA May Now Be Legally Required to Have an AML Program. Here's What That Means.

As of January 1, 2026, SEC-registered investment advisers and exempt reporting advisers with U.S. connections are subject to FinCEN's new AML rule. The deadline has passed. If your advisory firm hasn't acted yet, here is what the rule requires, why the window to comply quietly is closing, and what a practical AML program looks like for an RIA.

Elena Vargas

May 16, 2026 • 9 min read

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The OCC Just Rewarded Well-Run BSA Programs. Here's What That Actually Means.
FinCEN & RegulationOCC Policy Update

The OCC Just Rewarded Well-Run BSA Programs. Here's What That Actually Means.

In November 2025, the OCC updated its community bank BSA/AML examination procedures to allow examiners to carry forward prior conclusions for up to one cycle when a bank's risk profile hasn't materially changed. This is not a pass. It is a reward — and it only applies to institutions that were already doing it right.

OCCBSA Examination
EV
Elena Vargas

May 16, 2026

8 min read
OFAC Sanctions Compliance Is No Longer Just for Banks: What Schools, Businesses, and Professional Services Can Learn from IMG Academy's $1.7M Settlement
Compliance StrategyOFAC Enforcement

OFAC Sanctions Compliance Is No Longer Just for Banks: What Schools, Businesses, and Professional Services Can Learn from IMG Academy's $1.7M Settlement

Most businesses assume OFAC sanctions compliance is a bank problem. IMG Academy's $1.7 million settlement proves otherwise. When a world-renowned sports academy gets penalized for accepting tuition payments from sanctioned-country nationals, it signals that OFAC's enforcement reach has expanded far beyond financial institutions - and that any business accepting international payments needs to rethink its exposure.

OFAC SanctionsOFAC Compliance
AG
Argenis Galez

May 15, 2026

10 min read
What Happens After a Bad AML Program Review: A Recovery Checklist
Compliance StrategyRecovery Guide

What Happens After a Bad AML Program Review: A Recovery Checklist

You had a review. The report came back with findings - or you have since realized the review itself was inadequate. Either way, you are now in recovery mode. This is the step-by-step checklist for what to do next: how to assess the damage, prioritize the fixes, document the remediation, and rebuild a program that will hold up the next time someone looks at it.

AML RecoveryAML Remediation
EV
Elena Vargas

May 12, 2026

10 min read
What a Real AML Program Review Should Include (And What to Do If Yours Didn't)
Compliance StrategyBuyer's Guide

What a Real AML Program Review Should Include (And What to Do If Yours Didn't)

A genuine AML program review is not a document scan. It is a structured evaluation of whether your program actually works - not just whether it exists on paper. If you have had a review and are not sure it covered the right ground, this is the standard it should have been held to.

AML Program ReviewBSA Compliance Review
EV
Elena Vargas

May 12, 2026

9 min read
Questions to Ask Before Hiring an AML Compliance Firm
Compliance StrategyBuyer's Guide

Questions to Ask Before Hiring an AML Compliance Firm

Not every AML consulting firm delivers what it promises. Some sell templates as custom programs. Some lack the industry-specific expertise your business actually needs. And some will leave you more exposed than you were before you hired them. These are the questions that separate the firms worth hiring from the ones worth avoiding.

AML Compliance FirmHiring AML Consultant
EV
Elena Vargas

May 12, 2026

9 min read
Why Getting an AML Policy Without a Risk Assessment First Is a Major Red Flag
Compliance StrategyBuyer Beware

Why Getting an AML Policy Without a Risk Assessment First Is a Major Red Flag

If an AML firm hands you a finished compliance policy before they have spent serious time understanding your business, that is not a service - it is a liability. A policy built without a proper risk assessment is a template with your name on it, and it will not protect you when a regulator walks through the door.

AML PolicyRisk Assessment
EV
Elena Vargas

May 12, 2026

8 min read
FinCEN Issues Notice on the Threat of Human Trafficking During the 2026 FIFA World Cup
FinCEN & RegulationFinCEN Alert

FinCEN Issues Notice on the Threat of Human Trafficking During the 2026 FIFA World Cup

Today, the Financial Crimes Enforcement Network (FinCEN) issued a Notice urging increased vigilance by financial institutions located in and around cities hosting the 2026 FIFA World Cup. With millions of foreign and domestic visitors expected, the surge in economic activity creates conditions that traffickers historically exploit. Financial institutions are the front line of defense, and FinCEN has identified specific red flags and transaction patterns that compliance teams should be watching for now.

FinCENHuman Trafficking
EV
Elena Vargas

May 11, 2026

9 min read
BSA/AML Audit Simulator: Test Your Compliance Program Before the Examiner Does
Compliance Strategy

BSA/AML Audit Simulator: Test Your Compliance Program Before the Examiner Does

Most businesses discover their AML gaps during a regulatory examination - the most expensive possible time to find out. The BSA/AML Audit Simulator is a free interactive tool that evaluates your program against FinCEN's five-pillar framework in under 10 minutes, scores your readiness, and tells you exactly what to fix before an examiner walks through your door.

BSA AML Audit SimulatorAML Compliance Audit Tool
EV
Elena Vargas

May 4, 2026

8 min read
FinCEN's Residential Real Estate Rule Was Vacated. Here's What Title Companies Should Do Now.
Real EstateBreaking: March 2026

FinCEN's Residential Real Estate Rule Was Vacated. Here's What Title Companies Should Do Now.

On March 19, 2026, a federal court vacated FinCEN's Residential Real Estate Rule in Flowers Title Companies, LLC v. Bessent. The rule is not currently in effect. But vacated does not mean dead - and title companies that treat this as permanent relief are making a strategic mistake. Here are the three ways the rule could return, and what you should be doing while you wait.

FinCEN Real Estate RuleResidential Real Estate Reporting
AG
Argenis Galez

April 23, 2026

8 min read
FinCEN Proposes Whistleblower Rule: What It Means for Your Business, Your Employees, and the Future of AML Enforcement
FinCEN & RegulationBreaking: March 2026

FinCEN Proposes Whistleblower Rule: What It Means for Your Business, Your Employees, and the Future of AML Enforcement

On March 30, 2026, FinCEN submitted a Notice of Proposed Rulemaking to fully implement its whistleblower program, offering 10 to 30 percent of collected penalties to individuals who report BSA violations, sanctions breaches, and other financial crimes. This is the most significant shift in AML enforcement incentives in years. Here's what it means for everyone.

FinCEN WhistleblowerNPRM 2026
AG
Argenis Galez

April 19, 2026

9 min read
FinCEN's BOI Reporting Rule Was Just Vacated. Here's What That Actually Means for Your Business.
FinCEN & RegulationBreaking: April 2026

FinCEN's BOI Reporting Rule Was Just Vacated. Here's What That Actually Means for Your Business.

A federal court blocked the Corporate Transparency Act's beneficial ownership reporting requirement in March 2026. FinCEN has confirmed that filing is not currently required and there is no liability for not filing while the order stands. But this can change quickly, and businesses that aren't prepared will be caught flat-footed.

BOI ReportingCorporate Transparency Act
AG
Argenis Galez

April 18, 2026

7 min read
FinCEN's New Real Estate Reporting Rule: What Every Real Estate Professional Needs to Know
Real EstateNew Rule - Dec 2025

FinCEN's New Real Estate Reporting Rule: What Every Real Estate Professional Needs to Know

FinCEN's Residential Real Estate Rule became effective December 1, 2025, replacing the patchwork of Geographic Targeting Orders with a permanent, nationwide reporting requirement. If you're a title company, settlement agent, closing attorney, or real estate professional involved in all-cash transactions, your obligations changed. Here's exactly what the new rule requires and what you need to do now.

FinCEN Real Estate RuleResidential Real Estate Reporting
EV
Elena Vargas

April 17, 2026

10 min read
What Is a FinCEN Gap Analysis? (And Does Your Business Need One?)
FinCEN & Regulation

What Is a FinCEN Gap Analysis? (And Does Your Business Need One?)

A FinCEN gap analysis is one of the most searched compliance terms - and one of the least understood. If you've heard the phrase from a regulator, a banking partner, or a consultant and aren't sure what it actually means or whether you need one, this is the complete explanation.

FinCEN Gap AnalysisAML Program Review
EV
Elena Vargas

April 17, 2026

8 min read
What Is a Suspicious Activity Report (SAR)? The Complete Guide
AML Basics

What Is a Suspicious Activity Report (SAR)? The Complete Guide

A Suspicious Activity Report is one of the most important - and most misunderstood - obligations in the Bank Secrecy Act. Most businesses that are required to file SARs don't fully understand when they're required, what they must contain, or what happens after they're filed. This is the complete explanation.

SAR FilingSuspicious Activity Report
MR
Marcus Reid

April 15, 2026

9 min read
What Is Customer Due Diligence (CDD)? The Plain-English Guide for 2026
AML Basics

What Is Customer Due Diligence (CDD)? The Plain-English Guide for 2026

Customer Due Diligence - CDD - is one of the five mandatory elements of a BSA-compliant AML program, and it's the one most businesses get wrong. Not because it's complicated, but because the regulatory standard is higher than most businesses realize. Here's exactly what CDD requires and how to do it correctly.

Customer Due DiligenceCDD Rule
SD
Sofia Delgado

April 12, 2026

8 min read
What Is an MSB? The Complete Guide to Money Services Business Classification
MSB

What Is an MSB? The Complete Guide to Money Services Business Classification

Thousands of businesses in the United States are operating as Money Services Businesses without knowing it. The MSB classification under the Bank Secrecy Act is broader than most people expect - and the consequences of operating as an unregistered MSB are serious. Here's how to know if your business qualifies.

MSB ClassificationMoney Services Business
MR
Marcus Reid

April 10, 2026

8 min read
What Happens If Your Company Fails an AML Audit?
Compliance Strategy

What Happens If Your Company Fails an AML Audit?

Most business owners think of an AML audit failure as a bureaucratic inconvenience - a findings letter, some corrective actions, a follow-up visit. The reality is considerably more serious, and the consequences can unfold over years. Here's exactly what regulators do when they find a program with serious deficiencies.

AML AuditEnforcement Actions
EV
Elena Vargas

March 25, 2026

9 min read
What Is an AML Program and Who Needs It in 2026?
AML Basics

What Is an AML Program and Who Needs It in 2026?

If you've ever Googled "do I need an AML program," you're already ahead of most. The majority of businesses that face regulatory action for AML deficiencies didn't know they had a problem - because they didn't know they had an obligation. The definition of who's covered is broader than most business owners expect.

AML ProgramBSA Compliance
MR
Marcus Reid

March 12, 2026

7 min read
AML Compliance Checklist for Small Businesses (2026)
AML Basics

AML Compliance Checklist for Small Businesses (2026)

Small businesses that fall under the Bank Secrecy Act often assume that AML compliance is for big banks with dedicated compliance departments. That assumption is one of the most expensive mistakes in financial compliance. Regulators apply the exact same five-element framework to a 10-person MSB that they apply to a regional bank.

AML ChecklistSmall Business Compliance
SD
Sofia Delgado

March 1, 2026

6 min read
How to Perform an AML Risk Assessment in 2026 (Step-by-Step)
Compliance Strategy

How to Perform an AML Risk Assessment in 2026 (Step-by-Step)

The AML risk assessment is the single most important document in your compliance program - and it's the first thing a competent examiner evaluates. If it doesn't accurately reflect your actual business, every policy and procedure built on top of it is suspect. Here's how to build one that holds up under scrutiny.

Risk AssessmentAML Framework
EV
Elena Vargas

February 18, 2026

8 min read
AML Requirements for Mortgage Loan Originators (MLOs): The 2026 Breakdown
Mortgage

AML Requirements for Mortgage Loan Originators (MLOs): The 2026 Breakdown

Mortgage loan originators sit in one of the most unusual compliance positions in financial services - subject to BSA obligations but processing transactions that look nothing like a bank's. The regulatory framework was designed with banks in mind, but you're expected to apply it anyway. Here's what that actually means for your operation.

Mortgage ComplianceMLO
SD
Sofia Delgado

February 5, 2026

7 min read
AML Compliance for Fintech Startups: What You Need Before Launch
Fintech

AML Compliance for Fintech Startups: What You Need Before Launch

Every fintech founder says the same thing: "we'll build out compliance once we get traction." It's an understandable priority call - you have limited runway and a product to ship. But compliance is one of the few areas where getting it wrong early creates problems that money literally can't fix.

Fintech ComplianceAML Startup
MR
Marcus Reid

January 22, 2026

7 min read
MSB Compliance Checklist: Everything You Need to Stay Legal in 2026
MSB

MSB Compliance Checklist: Everything You Need to Stay Legal in 2026

Money Services Businesses face a compliance environment unlike almost any other industry in the U.S. - federal oversight from FinCEN, IRS examination authority, state licensing requirements, and banking relationship scrutiny, all running simultaneously. Here's the complete checklist for staying on the right side of all of them.

MSB ComplianceFinCEN Registration
MR
Marcus Reid

January 8, 2026

8 min read
5 Costly AML Mistakes That Can Shut Down Your Business
Compliance Strategy

5 Costly AML Mistakes That Can Shut Down Your Business

After reviewing AML programs across hundreds of South Florida businesses, the same five mistakes appear repeatedly in enforcement actions and examination findings. These aren't obscure regulatory technicalities - they're foundational failures that businesses make because they don't know what they don't know.

AML MistakesCompliance Risk
EV
Elena Vargas

December 20, 2025

7 min read
AML Compliance Requirements in Florida: The 2026 Guide
FinCEN & Regulation

AML Compliance Requirements in Florida: The 2026 Guide

Florida's proximity to Latin America, its concentration of international capital, and its cash-intensive economy make it one of the most scrutinized states in the country from an AML perspective. Here's what operating a financial business in Florida means for your compliance obligations in 2026.

Florida AML ComplianceFinCEN Florida
SD
Sofia Delgado

December 5, 2025

8 min read
How to Build an AML Program From Scratch (Step-by-Step Guide)
AML Basics

How to Build an AML Program From Scratch (Step-by-Step Guide)

Building an AML program from scratch sounds more complicated than it is - but not building one is considerably more complicated than most business owners realize. If your business has BSA obligations and you don't yet have a formal written program, this is your framework for building one that passes examination.

Build AML ProgramBSA Compliance
EV
Elena Vargas

November 18, 2025

9 min read
Why Regulators Want Variable BSA/AML Certificates - And Why Yours Should Be Too
Compliance Strategy

Why Regulators Want Variable BSA/AML Certificates - And Why Yours Should Be Too

A generic certificate that says "completed AML training" tells an examiner almost nothing. Regulators increasingly want to see certificates that reflect what was actually trained, who received it, and when - and businesses that can produce variable, role-specific certificates are consistently better positioned in examinations. Here's why that distinction matters more than most compliance officers realize.

BSA Training CertificatesAML Training Documentation
EV
Elena Vargas

April 11, 2026

8 min read
Your AML Compliance New Year Checklist for 2024
Compliance Strategy

Your AML Compliance New Year Checklist for 2024

The start of a new year is the right time to review your AML program, update your risk assessment, and confirm that your training cycle is on track. Here's the complete checklist for starting 2024 in compliance.

AML ChecklistNew Year Compliance
EV
Elena Vargas

January 3, 2024

6 min read
State Money Transmitter License Requirements: A 50-State Overview
MSB

State Money Transmitter License Requirements: A 50-State Overview

Money transmitter licensing is one of the most complex compliance obligations in financial services. Requirements vary dramatically by state, and operating without a required license exposes both the company and its officers to serious consequences.

Money Transmitter LicenseState Licensing
MR
Marcus Reid

December 7, 2023

8 min read
Your AML Compliance New Year Checklist for 2023
Compliance Strategy

Your AML Compliance New Year Checklist for 2023

Starting the year right means reviewing your AML program, confirming your training schedule, and making sure your risk assessment reflects your current business. Here's the complete checklist for 2023.

AML ChecklistNew Year Compliance
MR
Marcus Reid

January 11, 2023

6 min read
The Most Common AML Program Gaps We Found in 2022
Compliance Strategy

The Most Common AML Program Gaps We Found in 2022

After reviewing dozens of AML programs across multiple industries in 2022, the same gaps appear repeatedly. Here's what we found most often - and what it means for your program.

AML Program GapsCompliance Deficiencies
EV
Elena Vargas

August 30, 2022

6 min read
Community Voices

Published Articles

Expert perspectives from compliance professionals and industry leaders.

Guest Contributor4 articles
Building a Risk-Based AML Framework for Small MSBs
MSB AML Risk Framework
Guest Contributor

Building a Risk-Based AML Framework for Small MSBs

A risk-based AML framework is the foundation of every compliant money services business. Too many small MSBs treat compliance as a checkbox …

MSB AML Risk Framework
JC

James C. Whitfield

Whitfield Compliance Group

2 min read

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