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On Friday, Acting FDIC Chairman Travis Hill sent a letter to the Financial Crimes Enforcement Network (FinCEN) expressing support for allowing more flexibility with respect to certain Customer Identification Program (CIP) requirements for bank-fintech partnerships. Specifically, Acting Chairman Hill expressed support for generally allowing the collection of the last four digits of a Social Security number from a customer, rather than the full nine digits -- the approach permitted for credit card customers.

The letter states, “Aligning regulatory requirements to modern onboarding processes is long overdue. Federal authorities have long allowed banks to onboard credit card customers in this way; I support extending this approach more broadly . . . I look forward to working with our regulatory partners to modernize our approach to reflect private sector innovation in providing customer access to financial services.”

[Editor's note: Hill's letter made no mention of the requirement to obtain the full TIN of a customer when the account type (deposit or loan) will require the reporting to the IRS of interest paid to or by the customer.]

• FDIC Press Release

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.

The Treasury Department has released a letter sent by the Department to members of Congress in response to concerns surrounding the ongoing "DOGE" review of operations of the Bureau of the Fiscal Service by Tom Krause, a "special government employee" of the Treasury Department.

The NCUA on Friday reported it issued one prohibition notice in January 2025. Shana M. Ware, formerly employed by Genisys Credit Union, Auburn Hills, Michigan, was notified that, because she had been convicted in October 2024 of one count of Embezzlement from a Financial Institution, one count of Forgery, and one count of Embezzlement by an Agent or Trustee of $20,000 to $50,000 related to her misconduct at the credit union, she is prohibited by law from becoming an institution-affiliated party of any insured depository institution.

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.

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.

FinCEN has updated one of the alerts on its Beneficial Ownership Information Reporting webpage to acknowledge the Supreme Court's January 23, 2025, stay of a nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland).

Although various reports have suggested that the SCOTUS action would allow FinCEN to again require entities subject to the regulation to file reports, FinCEN's Alert notes a separate nationwide order issued by a different federal judge in Texas (Smith v. U.S. Department of the Treasury) still remains in place, and reporting companies are not currently required to file beneficial ownership information with FinCEN despite the Supreme Court’s action in Texas Top Cop Shop.

Reporting companies also are not subject to liability if they fail to file this information while the Smith order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.

Last week, the CFPB released a Compendium of Recent CFPB Guidance, including CFPB Circulars, Bulletins, Advisory Opinions, and Interpretive Rules issued from November 2021 through December 2024. The Compendium comprises 42 documents issued by the Bureau during that period for a total of 363 pages in a PDF format.