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According to industry analysis, the FDIC has intensified enforcement actions against financial institutions involved in bank-fintech partnerships, with 2025 marking a notable shift toward more public and prescriptive consequences. Previously, enforcement typically took the form of non-public supervisory actions or early-stage warnings. The FDIC now requires BaaS institutions to maintain complete inventories of fintech partners, conduct regular testing of controls, equip compliance teams with appropriate training and access to partner data, and clearly define roles and responsibilities. The agency continues to emphasize that banks bear ultimate responsibility for their fintech and middleware partners regarding BSA/AML, KYC, and consumer protection obligations.

Verified from source: The FDIC adopted more visible and prescriptive enforcement approaches in 2025 against banks involved in BaaS/fintech partnerships, shifting from non-public supervisory actions to more public consequences, with specific actions against a Pennsylvania bank and a California bank for BSA/AML deficiencies tied to third-party risk management.