FinCENGuidance/Enforcement Suspensionmedium

US financial institutions (general)

The US Financial Crimes Enforcement Network (FinCEN) announced a temporary suspension of supervisory and enforcement action against US financial institutions for certain technical breaches of the Bank Secrecy Act, USA PATRIOT Act, and related FinCEN regulations when those breaches arise from providing financial services to Venezuela. The policy took effect July 27, 2026 and runs through January 29, 2027. It applies only to institutions that are currently complying or making reasonable efforts to comply with applicable BSA requirements, have not been subject to a final FinCEN enforcement action for BSA breaches in the last 24 months, and continue to comply with OFAC sanctions and regulations. This is a material enforcement-policy change for banks and other covered financial institutions handling Venezuela-related activity.

Verified from source: FinCEN committed to not taking supervisory or enforcement action against US financial institutions for breaches of the Bank Secrecy Act, USA Patriot Act, and FinCEN regulations arising from providing Venezuela-related financial services. The page is paywalled but the title and visible content substantively confirm the action, though the page date is July 29, 2026 rather than July 27.

Implications
  1. Banks and BaaS providers offering services connected to Venezuela-related activity may temporarily face reduced BSA enforcement risk
  2. Financial institutions must still maintain OFAC compliance and demonstrate reasonable BSA compliance efforts to benefit from the suspension
  3. Sponsor banks facilitating fintech-driven cross-border payments to Venezuela could see expanded operational flexibility during the suspension period
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