BSA/AML/CFT & OFAC Compliance Policy
Updated 06/12/2026
This policy summarizes the BSA, AML/CFT and OFAC Compliance requirements.
Rule: Bank Secrecy Act (31 USC 5311), Foreign Assets Control Regulations (OFAC – 31 CFR 500), USA Patriot Act, Anti-Money Laundering Act of 2020, FFIEC BSA/AML Manual; FinCEN the Bank Secrecy Act Statutes;
Toolkit: BSA AML OFAC, New Accounts – Consumer, New Accounts – Commercial
Keywords: Anti-Money Laundering, Countering the Financing of Terrorism (AML/CFT), Bank Secrecy Act, BSA, Office of Foreign Assets Control, OFAC, Money Laundering, Terrorist Financing, USA PATRIOT Act
4/2/2026 –
Updated to include:
- FinCEN Orders Under the Fend Off Fentanyl Act, effective October 20, 2025.
- Updated to add note referencing FinCEN Exceptive Relief (FIN-2026-R001), issued February 13, 2026.
- Added “OFAC Screening for Instant Payments” section
6/12/2026 – Note: On May 19, 2026, President Trump issued Executive Order 14406, Restoring Integrity to America’s Financial System. Subsequently, FinCEN, jointly with the FDIC and OCC, issued Joint Advisory FIN-2026-A002 addressing BSA/AML risks associated with non-work-authorized populations, and the CFPB issued its Statement on Ability to Repay and Immigration Status regarding the consideration of immigration status and repayment risk in underwriting decisions. As of this writing, additional guidance regarding related credit-risk management expectations remains pending.
Members Can Download This Tool
Login to Download
Not Yet a Member?
Our members enjoy:
On-demand regulatory guidance hotline – by chat, phone and email – available from anywhere, on any device – 7 am - 6 pm, M-F, Central time
Research time saved daily & weekly across forms, checklists, and trainings — for every regulation
Hours of form-building and branding of bank documents saved; in some cases, even the budget of additional staff
A sounding board for support and reassessment when institutional goals or the regulatory environment changes
Access to attorneys and compliance specialists for risk modelling and decision-making in advance of large business decisions
The knowledge that C/A was created and owned by 30 State Bankers Association to provide bank compliance services to their membership organizations
Find out how a personalized team of attorneys and compliance professionals helps build targeted compliance strategies throughout your institution when you take our Live Membership Demo.