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The Federal Trade Commission reports it has sent letters to operators of websites that sell Employer Identification Number (EIN) filing and delivery services warning that some of their practices may violate the FTC Act and the Impersonation Rule, which prohibit posing as or misrepresenting affiliation with a government agency. According to the letters, these services charge consumers up to $300 per EIN even though consumers can obtain EINs for free directly from the Internal Revenue Service’s website.

FinCEN has announced it has issued FIN-2025-Alert001, FinCEN Alert on Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations, urging financial institutions to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by Mexico-based transnational criminal organizations (TCOs).

The Alert highlights one of several typologies that TCOs use to launder illicit proceeds generated in the United States through the cross-border movement of cash and how these operations enable the TCOs to place, layer, and integrate their illicit proceeds into the United States and Mexican financial systems where they can be accessed again to fund their criminal enterprises. It provides an overview of methodologies associated with these operations, highlights red flag indicators, and reminds financial institutions of their reporting requirements under the Bank Secrecy Act.

The OCC has announced its offering of six community bank director and senior management workshops.

Yesterday, FinCEN announced it has issued Advisory FIN-2025-A001 to help financial institutions identify and report suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS).

The Advisory highlights how ISIS and its global affiliates fund themselves and receive financial support from sympathizers internationally and describes several typologies ISIS uses to transfer money between its affiliates. The Advisory also provides red flags that may assist financial institutions in identifying related suspicious activity.

The OCC has released a list of 18 Community Reinvestment Act (CRA) performance evaluations that became public in March. Ten of those evaluations received ratings of Satisfactory.

We congratulate the remaining eight of the institutions for having evaluations that received ratings of Outstanding:

• Barrington Bank & Trust Company, National Association, Barrington, IL
• Beverly Bank & Trust Company, National Association, Chicago, IL
• Central Savings, F.S.B., Chicago, IL
• First Dakota National Bank, Yankton, SD
• First Pioneer National Bank, Wray, CO
• Fulton Bank, National Association, Lancaster, PA
• Patrons Bank, National Association, Okmulgee, OK
• The Santa Anna National Bank, Santa Anna, TX

The Federal Housing Finance Agency has, in the past several days, rescinded three of its 2024 Advisory Bulletins:

• AB 2024-01 (Climate-Related Risk Management), rescinded March 25, 2025
• AB 2024-04 (Federal Home Loan Bank System Climate-Related Risk Management), rescinded March 27, 2025
• AB 2024-06 (Regulated Entity Unfair or Deceptive Acts or Practices Compliance), rescinded March 24, 2025

Additionally, the FHFA has posted a notice on the front page of its site that it is "in the process of rescinding or revising guidance and policies posted on this webpage in accordance with Executive Order 14151 Ending Radical and Wasteful Government DEI Programs and Preferencing, and Executive Order 14168 Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government. In the interim, any previously issued diversity, equity, inclusion or gender-related guidance on this website should be considered rescinded."

Yesterday, the Department of the Treasury reported that OFAC, in coordination with the U.S. Department of Justice, has targeted a network of six entities and two individuals based in Iran, the United Arab Emirates, and the People’s Republic of China responsible for the procurement of unmanned aerial vehicle (UAV) components on behalf of Iran-based Qods Aviation Industries (QAI)—a leading manufacturer for Iran’s UAV program. This network has also facilitated procurement for other entities in Iran's military-industrial complex.

For a link to identification information on the designated individuals and entities, see yesterday's BankersOnline OFAC Update.

The Federal Reserve Board has announced it has issued a Consent Order of Prohibition against Nicolas Pérez Alvarado, a former deputy operations manager of a Banco Popular de Puerto Rico, based upon his having pleaded guilty to ten counts of aggravated illegal appropriation and embezzlement under Puerto Rico law for misappropriating $19,800 from the bank (repaid by Pérez Alvarado), and subsequent sentencing to probation.

The Board also announced its termination of a 2022 Cease and Desist Order against Allegiant United Holdings, LLC, Nano Financial Holdings, Inc., and Nano Banc, all of Irvine, California.

The NCUA has announced it issued four consent orders and two prohibition notices in March 2025 to individuals who are now prohibited from participating in the affairs of any federally insured depository institution. The orders and notices were issued against:

• Lindsay Risinger, a former employee of Barton Plan Employees Federal Credit Union in Luling, Louisiana
• Stephen Hopkins, a former employee of HealthPlus Federal Credit Union in Jackson, Mississippi
• Edward Nurse, a former employee of Park Side Financial Credit Union in Whitefish, Montana
• Nadaje Hendrix, a former employee of Hanscom Federal Credit Union in Middlesex, Massachusetts
• Jovan Eric Bell, a former employee of Navy Federal Credit Union in Vienna, Virginia
• Jalen Craig McMillan, a former employee of Navy Federal Credit Union in Vienna, Virginia

The OCC yesterday reported it has withdrawn its participation in the interagency principles for climate-related financial risk management for large financial institutions.

"The principles providing guidance to banks for climate-related financial risk are overly burdensome and duplicative. The OCC’s existing guidance for banks to maintain a sound risk management framework applies to all activities conducted by supervised institutions and includes potential exposures to severe weather events or natural disasters,” said Acting Comptroller of the Currency Rodney E. Hood."

The CFPB has announced that the Home Mortgage Disclosure Act (HMDA) Modified Loan Application Register (LAR) data for 2024 are now available on the Federal Financial Institutions Examination Council's (FFIEC) HMDA Platform for approximately 4,898 HMDA filers.

The published data contain loan-level information filed by financial institutions and modified to protect consumer privacy. A downloadable modified LAR file is available for every financial institution that has completed a HMDA data submission in the selected year. The modified LAR data represents the most current HMDA submission made by an institution.

Typically, some data resubmissions to correct errors occur during the weeks following the annual submission deadline. For this reason, data users may want to wait for the release of the Snapshot National Loan-Level Dataset to analyze the nationwide data.

The Department of the Treasury has announced that OFAC has designated six individuals and seven entities involved in a money laundering network supporting the Sinaloa Cartel. The Sinaloa Cartel is responsible for a significant portion of the illicit fentanyl and other deadly drugs trafficked into the United States and has exploited multiple ports of entry along the southern border for its criminal activities.

Treasury also reported that FinCEN had issued an alert urging financial institutions to be vigilant to bulk cash smuggling and repatriation by Mexico-based transnational criminal organizations. The alert outlines methodologies associated with these operations and highlights red flag indicators in an effort to better equip financial institutions to counter this illicit activity.

• Chart of the Sinaloa Cartel Money Laundering Network

The Department of State announced its designation of six individuals who have engaged in actions or policies that threaten to further erode the autonomy of Hong Kong in contravention of China’s commitments, and in connection with acts of transnational repression.

For a link to names and identification information on the OFAC and State Department designated parties, see the March 31, 2025, BankersOnline OFAC Update.

The Department of Housing and Urban Development Office of Housing, Multifamily Housing, and Office of Public and Indian Housing have published [90 FR 14376] in this morning's Federal Register a notice of a new matching program between the U.S. Department of Housing and Urban Development (HUD) and the Department of the Treasury, Bureau of the Fiscal Service, Do Not Pay (DNP) Treasury Working System.

This program aims to enhance the detection and prevention of fraud, waste, abuse and improper and unsupported payments in Federal benefit programs administered by HUD. Comments on the notice must be received no later than May 1, 2025. If no public comments are received by that time, the new agreement will become effective on May 1, 2025.

The CFPB has stated it plans to revoke its "Use of Digital User Accounts to Access Buy Now, Pay Later Loans" interpretive rule [89 FR 47068, May 31, 2024] in a Status Report and Joint Motion to Stay in Financial Technology Association v. Consumer Financial Protect Bureau in the U.S. District Court for the District of Columbia.