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The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced it has assessed a $37,000,000 civil money penalty against Brink’s Global Services USA, Inc. (Brink’s) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. As a result of Brink’s failures, hundreds of millions of dollars in bulk currency shipments were transmitted across the Southwest Border on behalf of high-risk entities—including a Mexican currency exchanger that later pleaded guilty to violating the BSA. This is FinCEN’s first enforcement action against an armored car company.

The U.S. Attorney's Office for the Southern District of California, in a coordinated announcement, reported that Brink's Global Services USA agreed to forfeit over $50 million under a Non-Prosecution Agreement to settle criminal allegations that it operated as an unlicensed money transmitting business.

After current and potential future credits toward the forfeiture. and FinCEN partial credit of some of the Department of Justice forfeiture toward its civil money penalty, the net cost to the company appears to be $42 million.

For additional information and links to the FinCEN order and the Justice Department agreement, see "Brink's Global Services USA pays $42M for BSA violations" in our Penalty pages.

Yesterday, the Treasury Department reported that OFAC has sanctioned an international network for facilitating the shipment of millions of barrels of Iranian crude oil worth hundreds of millions of dollars to the People’s Republic of China (PRC). The oil was shipped on behalf of Iran’s Armed Forces General Staff (AFGS) and its sanctioned front company, Sepehr Energy Jahan Nama Pars (Sepehr Energy). This action includes entities and individuals in multiple jurisdictions, including the PRC, India, and the United Arab Emirates (UAE), as well as several vessels.

For a link to the names and identification information of the designated parties and vessels, see yesterday's BankersOnline OFAC Update.

The U.S. Department of State this morning published [90 FR 9101] a List of Restricted Entities and Subentities Associated With Cuba (Cuba Restricted List) with which direct financial transactions are generally prohibited under the Cuban Assets Control Regulations (CACR).

The Cuba Restricted List was initiated in 2017. It was rescinded January 16, 2025. On January 20, 2025, President Trump issued an Executive Order reinstating the list.

Yesterday, the Federal Reserve Board released the hypothetical scenarios for its annual stress test, which helps ensure that large banks can lend to households and businesses even in a severe recession. Additionally, the Board released two hypothetical elements designed to probe different risks through its "exploratory analysis" of the banking system. The exploratory analysis will not affect bank capital requirements.

The Board's annual stress test evaluates the resilience of large banks by estimating losses, net revenue, and capital levels—which provide a cushion against losses—under hypothetical recession scenarios that extend two years into the future. This year, 22 banks will be tested against a severe global recession with heightened stress in both commercial and residential real estate markets, as well as in corporate debt markets. The scenarios are not forecasts and should not be interpreted as predictions of future economic conditions.

In the 2025 stress test scenario, the U.S. unemployment rate rises nearly 5.9 percentage points, to a peak of 10 percent. The unemployment rate increase is accompanied by severe market volatility, a widening of corporate bond spreads, and a collapse in asset prices, including about a 33 percent decline in house prices and a 30 percent decline in commercial real estate prices. Large banks with substantial trading or custodial operations are also required to incorporate a counterparty default scenario component to estimate potential losses from the unexpected default of the firm's largest counterparty amid an acute market shock. In addition, banks with large trading operations will be tested against a global market shock component that primarily stresses their trading and related positions.

This morning, the FDIC released 175 documents related to its supervision of banks that engaged in, or sought to engage in, crypto-related activities.

Acting Chairman Travis Hill issued the following statement in connection with the release:

“I have been critical in the past of the FDIC’s approach to crypto assets and blockchain. As I said last March, the FDIC’s approach ‘has contributed to a general perception that the agency was closed for business if institutions are interested in anything related to blockchain or distributed ledger technology.’

“Upon becoming Acting Chairman, I directed staff to conduct a comprehensive review of all supervisory communications with banks that sought to offer crypto-related products or services. While this review remains underway, we are releasing a large batch of documents today, in advance of a court-ordered deadline of Friday. Our decision to release these documents reflects a commitment to enhance transparency, beyond what is required by the Freedom of Information Act (FOIA), while also attempting to fulfill the spirit of the FOIA request."

Hill said the FDIC is actively reevaluating its supervisory approach to crypto-related assets, including replacing Financial Institution Letter (FIL) 16-2022 and providing a pathway for institutions to engage in crypto- and blockchain-related activities while still adhering to safety and soundness principles.

The crypto-related activities documents are the first three items on the current list of records listed on the FDIC's FOIA Reading Room webpage.

The FDIC, OCC, and Federal Reserve Board have issued a joint press release announcing a virtual public outreach meeting on March 6, 2025, as part of their review of regulations, as required by law. The Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) requires the agencies, with input from the public, to review their regulations at least once every 10 years to identify any outdated or otherwise unnecessary regulatory requirements applicable to their supervised institutions.

The outreach meeting is an opportunity for interested stakeholders to present their views on the six categories of regulations listed in the first two Federal Register notices: Applications and Reporting; Powers and Activities; International Operations; Consumer Protection; Directors, Officers and Employees; and Money Laundering.

The FDIC regularly releases a monthly list of its enforcement orders and decisions near the end of the month following the issuance of the orders. On Friday, the FDIC issued its January 2025 list of orders and decisions issued in December 2024. Among those enforcement actions were—

• An order for assessment of a $650,000 civil money penalty against WEX Bank, Sandy, Utah, after a finding that the bank engaged in deceptive acts and unfair practices in violation of Section 5 of the Federal Trade Commission Act
• An order to pay a $47,000 civil money penalty against State Bank of DeKalb, DeKalb, Texas, after a finding that the bank violated HMDA and Regulation C, by failing to report accurate data about its HMDA-applicable denied, withdrawn, and incomplete applications for 2021 and 2022.
• An order modifying a 2023 order of prohibition and order to pay a civil money penalty against Diana Yates, formerly affiliated with The Bank of Oswego, Lake Oswego, Oregon. The order of prohibition was reissued; the civil money penalty was canceled.
• A consent order against Bank of Vici, Vici, Oklahoma
• An order for assessment of a $105,000 civil money penalty and removal/prohibition against Frank William Bonan II, former chairman of the board of Grand Rivers Community Bank, Grand Chain, Illinois
• An Notice of Charges and of Hearing for an order of restitution of $352,450 and prohibition directed to Danielle Solomon, affiliated with Truist Bank, Charlotte, North Carolina
• Removal/Prohibition orders against—
  • Nigar Scott, Truist Bank, Charlotte, North Carolina
  • Vicki L. Grisham, The First State Bank, Abernathy, Texas
  • Kelly M. Huffman, First Security Bank - West, Beulah, North Dakota (with order to pay civil money penalty of $15,000)
  • Oscar Gonzales Bono (with three aliases), NVE Bank, Englewood, New Jersey
  • Sharna L. Carter, First-Citizens Bank & Trust Company, Raleigh, North Carolina
  • Rodolpho R. Pagesy Roussel, Oriental Bank, San Juan, Puerto Rico
  • Barbara Lejeune Chaisson, JD Bank, Jennings, Louisiana
• Voluntary Termination of Deposit Insurance orders for Washington Business Bank, Olympia, Washington; TSB Bank, Lomira, Wisconsin; First National Bank Northwest Florida, Panama City, Florida; and Northside Community Bank, Burnee, Illinois

Yesterday, the CFPB issued a Stipulated Consent Order against Wise US Inc., the U.S. subsidiary of Wise PLC, a global electronic money services provider, ordering Wise to pay nearly $2.5 million for a series of illegal actions, including advertising inaccurate fees and failing to properly disclose exchange rates and other costs. Wise allows customers to send, receive, and store remittances through a mobile app and prepaid accounts and debit cards.

The CFPB found the company misled customers in the United States about its ATM fees and failed to properly disclose other fees. When people sent money that did not arrive on time, Wise failed to refund the remittance fees in the timeframe required by law. Overall, the company’s actions led to hundreds of thousands of dollars in harm to consumers. The CFPB is ordering Wise to pay approximately $450,000 in redress to harmed consumers and to pay a $2.025 million civil money penalty.

The CFPB found that Wise violated the Consumer Financial Protection Act of 2010 by advertising inaccurate ATM fees and charges to U.S. customers. The CFPB also found that Wise violated the Electronic Fund Transfer Act in a variety of ways, such as failing to properly disclose exchange rates and failing to refund fees when funds were not available to the recipient on time.

• Consent Order [56 page PDF]
• CFPB 1/30/2025 Press Release

Yesterday, FinCEN rescinded its two Alerts on Israeli Extremist Settler Violence Against Palestinians in the West Bank, published on February 1, 2024 and July 11, 2024, respectively. On January 20, 2025, the President signed a new Executive Order (E.O.), “Initial Rescissions Of Harmful Executive Orders And Actions,” which, among other actions, revoked E.O. 14115, “Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank.” Accordingly, FinCEN is no longer requesting that financial institutions file suspicious activity reports with the key term “FIN-2024-WBEXTREMISM.”

The two alerts remain on FinCEN's Alerts/Advisories/Notices/Bulletins/Fact Sheets webpage with annotations that they have been rescinded.

The Internal Revenue Service has announced yesterday's opening of the 2025 tax filing season, and the acceptance of federal individual tax year 2024 returns. As of yesterday's opening, IRS systems had already received millions of tax returns.

The IRS is again encouraging people to file their returns electronically and choose direct deposit for more secure, faster refunds, and suggests that paper refund checks are 16 times more likely to have an issue, such as the check's being lost, misdirected, stolen or uncashed. Filing electronically reduces tax return errors as the tax software does the calculations, flags common errors and prompts taxpayers for missing information.

Tax refunds are likely to start arriving in paper and direct deposit form by the end of February.