US TreasuryGuidancemedium

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In January 2026, the US Treasury intensified its focus on Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance at banks, with particular attention to fraud detection involving nonprofits and government funds. The scrutiny was informed in part by cases like the $250 million 'Feeding Our Future' fraud scheme. While not a direct enforcement action against a specific bank, this heightened supervisory posture raises compliance expectations for banks participating in BaaS arrangements, especially those whose fintech partners handle high-volume transactions that may involve government program funds. Banks are expected to strengthen their transaction monitoring and suspicious activity reporting capabilities.

Verified from source: On January 9, 2026, U.S. Treasury Secretary Scott Bessent announced new federal actions focused on fraud in federal aid programs, intensifying BSA/AML oversight of financial institutions, particularly those serving nonprofits and customers handling government-related funds, with FinCEN issuing targeted alerts and investigative demands.

Implications
  1. BaaS banks processing high-volume fintech transactions face increased BSA/AML compliance expectations
  2. Sponsor banks must ensure fintech partners' transaction flows are adequately monitored for fraud indicators
  3. Treasury focus on government fund fraud may affect fintechs in benefits disbursement or nonprofit payment processing
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