A Chaotic Start to September
If you are the BSA Officer at your institution, the first couple weeks of September started with a bang. FinCEN was on a roll and we want to make sure you didn’t miss anything!
September 2
- FinCEN issued a Joint Statement on SAR confidentiality considerations with respect to customer communication.
- FinCEN reissued the Government Targeting Order for money service businesses along the southwest border of the U.S. (with a few tweaks). On September 9th, the Frequently Asked Questions we also updated.
September 3
- FinCEN issued an Alert (FIN-2026-Alert005) on money laundering activity related to digital asset investment scam centers.
- FinCEN published a Financial Trend Analysis that identified approximately $12.7 billion in suspected digital asset investment scams in SARs filed from September 8, 2023, through December 31, 2025.
September 8
- FinCEN issued an Alert (FIN-2026-Alert006) regarding Iranian sanctions evasion of procurement networks for commercial aviation industry.
- FinCEN announced that it updated Frequently Asked Questions regarding treatment of verifiable digital credentials under the Customer Identification Program.
September 9
- FinCEN published Financial Trend Analysis on health care fraud which identified approximately $17.5 billion in suspected activity in SARs filed between March 1, 2025, through February 28, 2026.
September 10
- FinCEN issued a Whistleblower Bulletin on Iran-related illicit finance reminding institutions about the whistleblower incentive program, how to blow the whistle and things to look for.
We have to admit, the amount of information here is a bit overwhelming, even for us! We started covering a few of these topics during our September AML/CFT Membership Group meeting and plan to cover the rest in October so make sure you join us!
Published 2026/09/20
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!