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Banking executives reviewing payment activity and BSA/AML controls in a modern financial operations center.
BSA/AML & Financial Crime
October 22, 2026

OCC Enforcement Trends: When Growth Outpaces BSA/AML Controls

Two 2026 OCC consent orders deliver a clear message: when business complexity outpaces BSA/AML controls, enforcement follows. This executive brief examines the warning signs, board responsibilities, third-party risks, and practical growth gates banks should use to keep governance, staffing, systems, and independent assurance aligned with expanding payment, fintech, and cross-border activity.
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Bank board and audit committee reviewing AML program documentation under FinCEN's new effectiveness standard
BSA/AML & Financial Crime
July 31, 2026

FinCEN’s AML Overhaul: Why Boards Must Prove Effectiveness, Not Just Compliance

FinCEN’s April 2026 proposal reduces prescriptive requirements while increasing the evidentiary burden on boards, audit committees, and testing functions. The question is no longer whether the AML/CFT program exists, but whether the record behind its risk-based judgments holds.
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Bank audit committee reviewing a confidential document in a boardroom before a regulatory examination
Exam Readiness & Enforcement
July 22, 2026

Handling Highly Sensitive Information During Examinations: The Governance Questions Banks Should Consider

The Federal Reserve, FDIC, and OCC now expect bank management to raise concerns about information that management believes should receive special handling during examinations. Boards should set governance parameters before those decisions are made under exam pressure.
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Regulatory documents and gavel on an executive desk representing new interagency lending guidance and its audit implications.
Credit & Lending Risk
July 14, 2026

New Federal Lending Guidance: Immediate Audit Implications

New interagency guidance from the OCC, FDIC, and NCUA sharpens supervisory expectations for lending to individuals not legally authorized to work in the United States, and it takes effect immediately. The guidance does not prohibit such lending, but it raises the bar on underwriting, income verification, portfolio risk, and fair lending compliance. Here is what audit teams need to evaluate now.
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Conceptual image of a broken bridge symbolizing the CRA compliance and internal audit governance gap at financial institutions.
Consumer Compliance & Fair Lending
July 14, 2026

CRA Modernization Was Rescinded. The Audit Gap It Exposed Was Not.

Regulators abandoned the 2023 CRA modernization rule, but the preparation exposed longstanding governance, data, and oversight weaknesses that remain subject to examiner scrutiny. Institutions and their internal audit functions should revisit CRA now to confirm that two years of uncertainty did not create blind spots in an ongoing program.
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Frontier AI Models cause threat to financial institutions
AI & Emerging Technology
July 14, 2026

AI-Powered Adversaries: The New Risk to Community Financial Institutions

Frontier AI has put elite attack capabilities within reach of anyone, and community banks, credit unions, and fintechs inherit the risk whether or not they adopt the technology.
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UDAAP compliance audit review for community and regional financial institutions facing state enforcement and private plaintiff risk.
Consumer Compliance & Fair Lending
July 10, 2026

The CFPB Stepped Back on UDAAP. State Regulators and Private Plaintiffs Did Not.

The federal footprint has narrowed. The enforcement surface has not. Institutions that repriced consumer products in 2024 and 2025 without refreshing their Unfair, Deceptive, and Abusive Acts or Practices (UDAAP) audit coverage are the ones whose next examination will find the gap.
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BaaS and Fintech responsibilities during an Audit
Sponsor Bank & BaaS Oversight
January 30, 2026

Audit Readiness for BaaS Programs: What Regulators Are Actually Examining

Banking as a Service materially changes a bank’s risk profile by embedding fintech partners in regulated banking activities. Regulators have been explicit that sponsor banks remain fully accountable for compliance, operational integrity and control effectiveness, regardless of who performs the activity. This brief covers what examiners expect and how internal audit should expand its scope and testing for BaaS programs.
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