Regulatory Tracker

Regulatory Tracker — Page 5 of 10

Archive of enforcement actions, consent orders, and supervisory guidance impacting the BaaS and embedded finance ecosystem.

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California DFPI

The California DFPI imposed a $1 million penalty on Yotta Technologies on May 15, 2026, for falsely marketing customer accounts as FDIC-insured. Yotta had moved those accounts to Synapse Brokerage LLC, which filed for bankruptcy in April 2024.

Massachusetts Division of Banks

Bridge It Inc. dba Brigit

Cease and Desist / Settlement

The Massachusetts Division of Banks settled with Bridge It Inc. (dba Brigit) for $1.9 million over unlicensed third-party loan servicing dating back to at least July 2021. The company was ordered to cease unlicensed activity immediately.

Lietuvos bankas (Bank of Lithuania)

UAB Walletto

Administrative settlement

Lietuvos bankas imposed a €290,000 monetary sanction on UAB Walletto following a targeted inspection that found AML/CFT internal control weaknesses and client funds safeguarding deficiencies. The sanction was publicly disclosed.

Lietuvos bankas (Bank of Lithuania)

Lietuvos bankas introduced dedicated supervisory contact persons for selected EMIs and PIs to strengthen regulatory dialogue and improve supervisory consistency. The model is expected to expand to additional institutions.

FinCEN

FinCEN and OFAC jointly proposed a rule on April 8, 2026, under the GENIUS Act requiring payment stablecoin issuers to implement AML/CFT programs. The rule aligns stablecoin compliance obligations with bank-like standards for primary and secondary market risks.

PSR

The PSR fined Bank of Ireland UK £3,779,300 on Feb 19, 2026, for missing the Oct 2023 Confirmation of Payee deadline by 14 months. The bank was the last Group 1 provider to go live, activating CoP in January 2025.

Federal Reserve

The Federal Reserve began requesting detailed disclosures from major US banks on their exposures to private credit funds between April 18-22, 2026. Bank lending to non-bank financial institutions has reached approximately $1.4 trillion, representing around 11% of total US bank lending.

RBI

Paytm Payments Bank

Licence Revocation

The Reserve Bank of India cancelled the banking licence of Paytm Payments Bank Limited, effective Apr 24, 2026. The RBI cited persistent KYC failures, transaction limit breaches, and failure to meet licence conditions.

OCC | Federal Reserve | FDIC

On April 17, 2026, the OCC, Federal Reserve, and FDIC issued revised interagency guidance on model risk management, addressing vendor and third-party products. The guidance is relevant to bank-fintech relationships where models are sourced from or operated by third parties.

OCC, Federal Reserve, FDIC

On April 17, 2026, the OCC, Federal Reserve, and FDIC issued revised interagency guidance on model risk management. The guidance addresses sound principles for model development, validation, monitoring, and governance, including considerations for vendor and third-party products.

OCC

The OCC entered into a consent order with The Federal Savings Bank in Chicago over deceptive marketing of VA cash-out refinance loans between 2022 and 2024. The bank neither admitted nor denied the allegations.

Royal Monetary Authority (RMA)

Bhutan's Royal Monetary Authority fined Bank of Bhutan more than Nu 228 million for AML failures, including governance deficiencies and delayed suspicious transaction reporting. The bank also faces a dividend ban and mandatory system audits.

OCC

JPMorgan Chase

Termination of Consent Order

The OCC terminated a March 2024 enforcement action against JPMorgan Chase over failures to monitor trading activity on at least 30 global venues. The original action, paired with a Federal Reserve order, carried $348.2 million in penalties.

SEC

Unknown UK Bank

No-Action Relief / Guidance

On April 15, 2026, SEC staff issued no-action relief for a UK bank's bail-in, allowing exchange of bailed-in bonds for shares without Securities Act registration. SEC Chairman Atkins directed broader rulemaking for foreign bank resolutions.

FDIC

All FDIC-supervised institutions

Rescission of Guidance

The FDIC rescinded its prior guidance on non-sufficient funds (NSF) fees on April 10, 2026. This action removes previously issued supervisory expectations around NSF fee practices for FDIC-supervised institutions.

FDIC | OCC

The FDIC and OCC adopted a joint final rule prohibiting the agencies from taking adverse action against financial institutions based on reputation risk, including risk stemming from customers' political, social, cultural, religious views, or lawful business activities. The rule takes effect June 6, 2026.

Federal Reserve

Goldman Sachs

Termination of Enforcement Action

The Federal Reserve terminated its 2018 enforcement action against Goldman Sachs on April 10, 2026, citing improved compliance controls in FX trading operations. The original action had included a $54.75 million fine for unsafe practices and internal control gaps.

FinCEN / FDIC / OCC / NCUA

Industry-Wide (All Financial Institutions)

Proposed Rulemaking / Guidance

FinCEN, the FDIC, OCC, and NCUA jointly proposed a major overhaul of AML/CFT regulations, modernizing the framework for the first time since the 1970s Bank Secrecy Act. The proposal introduces a risk-focused approach, expands FinCEN's enforcement consultation role, and adds AML program requirements for payment stablecoin issuers.

FTC

FTC Chairman sent warning letters to PayPal, Stripe, Visa, and Mastercard against 'debanking' customers based on political or religious views, citing a Trump Executive Order and threatening FTC investigations.

FinCEN

Unknown Sponsor Bank

Proposed Rulemaking

On April 7, 2026, FinCEN proposed a rule to coordinate federal banking agencies' anti-money laundering (AML) oversight, potentially limiting enforcement to serious deficiencies in banks' BSA/AML programs. The proposal could indirectly affect bank-fintech AML compliance obligations.

FCA

The FCA fined Dinosaur Merchant Bank Limited £338,000 for market abuse and systems failures. The firm was categorized under electronic money and payment institutions.

FDIC

Industry-Wide

Speech/Guidance

The FDIC published a speech or update on reforms to its regulatory toolkit, potentially addressing BaaS and third-party risk management supervisory approaches.

SEC, CFTC

The SEC and CFTC signed a landmark memorandum of understanding on regulatory harmonization in March 2026, potentially affecting bank-fintech partnerships involving digital assets.

Central Bank of Nigeria (CBN)

The Central Bank of Nigeria released a Fintech Policy Insight Report on February 2, 2026, proposing collaborative regulation for fintechs. The report outlines a Standing Fintech Engagement Forum, a Compliance-as-a-Service platform, and an expanded regulatory sandbox.

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