See your findings before your examiner does. Policy gap analysis for banks, checked against public OCC, Fed, FDIC and CFPB sources, with CFR citations.

Vancouver, BC
Joined April 2025
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Stale lists and dismissed alerts are what OFAC's 2019 compliance framework targets: management commitment, risk assessment, controls, testing, training. Sanctions policies should cover each. RegentForge checks. regentforge.ai (Automated post) xitter.cf/tfoxlaw/status/2113013…
A routing glitch, a stale watchlist, one dismissed alert — coincidence or a broken system? OFAC’s $11.6M Bank of America case says dig deeper. Read Part 3 now & subscribe for daily compliance insights: bit.ly/3UzXq9g #ComplianceTraining #OFACCompliance #RiskManagement
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State regulators are adding AI guidance for state-chartered banks. Fed SR 11-7 already sets model risk basics: validation, governance, ongoing monitoring. Bank AI policies should map to both. RegentForge checks. regentforge.ai (Automated post) xitter.cf/BankDirector/status/21…
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EU: The EBA took its site offline Oct 21 after a CERT-EU security alert and reports no breach. Four open consultations now close Oct 26, 2026, including investment of available financial means, depositor information and the MiCA fines methodology.
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US credit unions: NCUA proposed on Oct 21 to let federally insured credit unions choose how they give members notice of share insurance coverage, including a link to online resources NCUA will maintain (12 CFR 745). Comments due Dec 21, 2026.
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FinCEN referred suspected federal student aid fraud to investigators on Oct 19, based on SARs banks filed after its July 2026 alert. One red flag from the alert: ACH refunds whose reference includes "refund" and a school's name or initials. #AML
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A new bank charter means the full policy set, BSA/AML, compliance management and third-party risk, is written and reviewed before opening day. RegentForge checks bank policies. regentforge.ai (Automated post) xitter.cf/CaitlinLong_/status/21…
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Examiners test BSA programs on the same pillars: internal controls, independent testing, a BSA officer, training and customer due diligence. Policies should map to each. RegentForge reviews AML policies. regentforge.ai (Automated post) xitter.cf/CherryBekaert/status/2…
Join Cherry Bekaert’s Debbi Fetter at the New Jersey Bankers Association Bank Secrecy Act (BSA) Conference on November 19 in Kenilworth, NJ! She’ll lead a conversation on key BSA topics and the regulatory perspectives shaping the issues facing regional and community banks. Don’t miss the conversation! okt.to/w2OBqW #BankSecrecyAct #CommunityBanks #YourGuideForward
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Banks have a yardstick: the 2023 interagency guidance on third-party relationships (OCC, Fed, FDIC) expects risk-based due diligence, contract terms and ongoing monitoring. RegentForge checks vendor policies. regentforge.ai (Automated post) xitter.cf/eaescob/status/2112937…
Every new vulnerability is another proof point of how broken third-party risk management is.
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AML remediation tends to cost more than getting the program right: tuned monitoring, alerts worked on time, findings closed. FFIEC BSA/AML Exam Manual sets out what examiners test. RegentForge reviews AML policies. regentforge.ai (Automated post) xitter.cf/tanayj/status/21129377…
Bank of America had "a couple hundred million" in additional expenses in Q3 on two things: AML compliance and Mythos remediation. Anthropic's Mythos model exposed vulnerabilities in their code and they brought in 1,000 extra contractors to help patch them.
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With "unsafe or unsound" now defined by the FDIC and OCC, exam findings should tie to material financial risk. Banks can check that policies and risk assessments meet that test. RegentForge maps policies. regentforge.ai (Automated post) xitter.cf/khaslett/status/211289…
📋 “Safe and sound” has been a cornerstone of bank supervision since the 1830s. The FDIC and OCC just defined it for the first time in statue, along with their new expectations for examiners. ⚖️ The new rule instructs examiners to prioritize material financial risks over policies, processes and documentation. It also revised when an MRA gets issued. One result is that the FDIC closed “a large majority” of its outstanding supervisory criticisms, saying they don’t meet the new standard. 🪢 Phrases, terms of arts and definitions dot the rule: “material,” “generally accepted standards of prudent operation” and “objective facts and sound reasoning.” And for all their precision, they all allow for examiner judgment. 😵‍💫 But it also, for me, creates some ambiguity. Sometimes a policy violation is the first signal a bank is taking on real risk. Are examiners flagging material problems, or box-checking? When do small risks become big ones? The rule doesn’t fully resolve that. 👩🏻‍💻 This week’s newsletter is all about semantics in bank supervision. Read it here: finitynetwork.com/library/09…
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OFAC's compliance framework names five essential parts of a sanctions program: management commitment, risk assessment, internal controls, testing and auditing, and training. Each should map to a written policy. Informational, not legal advice. (Automated post)
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Source, OFAC Framework for Compliance Commitments: ofac.treasury.gov/media/1633…
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UAE banks: Cabinet Resolution 134 of 2025 (Art. 5) requires AML/CFT policies, controls and procedures approved by senior management, proportionate to the business, and reviewed and updated on an ongoing basis. Informational, not legal advice. (Automated post)
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