Regulatory Tracker

Regulatory Tracker

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

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Reserve Bank of India (RBI)

The Reserve Bank of India issued new rules governing EMI default recovery practices, restricting how banks can lock customer devices and how recovery agents may contact borrowers. The guidance applies to commercial banks and sets specific notice periods before device restrictions can be imposed.

OCC

Bunq

Charter Application Rejection

A US banking regulator rejected Dutch fintech Bunq BV's application to operate as a national bank. Bunq had submitted the charter request at the beginning of the year.

FDIC

The FDIC is working with banking and fintech industry groups to develop an independent standard-setting body and voluntary rulebook for fintechs and third parties that partner with banks. The proposed standards would certify firms against baseline risk-management standards but carry no safe harbor.

OCC

Wells Fargo

Formal Agreement

The OCC and Wells Fargo signed a formal agreement on Sep 12, 2024, citing flaws in BSA/AML risk management, suspicious activity reporting, and OFAC sanctions compliance. The agreement requires Wells Fargo to submit a remedial action plan within 120 days.

FinCEN

UBS

Fine

FinCEN fined UBS US$125 million for alleged wilful AML compliance failures. The penalty, assessed on August 6, 2026, was reported as one of the largest AML fines of the year.

OCC

Bunq

Charter Denial

The OCC rejected Dutch fintech Bunq's application for a U.S. national bank charter in a letter dated Aug 04, 2026. The regulator cited supervisory and compliance concerns, including doubts about capitalization and management experience.

FDIC

The FDIC is advancing plans to create an industry-backed fintech certification body. The proposal establishes a standards and certification framework for fintechs partnering with banks.

FinCEN

FinCEN fined UBS $125 million for repeat anti-money laundering failures and Bank Secrecy Act violations. The penalty is FinCEN's largest against a broker-dealer for BSA violations.

OCC

Bank of America

Civil Money Penalty

Bank of America disclosed it faces potential new fines from the OCC over AML program deficiencies. The bank said it is continuing to discuss resolution of a consent order issued in Dec 2024.

FinCEN

UBS Financial Services

Civil Money Penalty

FinCEN imposed a record $125 million penalty on UBS Financial Services for repeated AML failures, including unmonitored foreign wire transfers and four years of uncorrected compliance deficiencies.

OCC

Bank of America

Consent Order

Bank of America disclosed in its SEC quarterly filing that it faces potential new fines tied to a December 2024 OCC consent order over AML deficiencies. The bank said it is continuing to discuss a resolution with the OCC.

FINRA

FINRA fined UBS Financial $20 million for anti-money laundering violations. The news release was published on Aug 03, 2026.

CFTC

The CFTC fined UBS Financial Services $8 million for failing to supervise AML transaction-monitoring systems. The order also requires the firm to cease and desist from further violations.

FinCEN

FinCEN imposed a $125 million civil penalty on the U.S. affiliate of UBS for Bank Secrecy Act violations on Aug 04, 2026. The agency called it the largest such penalty ever against a broker-dealer.

FinCEN

UBS Financial Services

Civil Money Penalty

FinCEN assessed a $125 million civil money penalty against UBS Financial Services on Aug 03, 2026, for willful violations of the Bank Secrecy Act. The agency called it the largest BSA penalty ever imposed on a broker-dealer.

European Commission AI Office

EU AI Act transparency obligations (Article 50) and the European Commission's enforcement powers over general-purpose AI providers became effective on August 2, 2026. The AI Office can impose fines up to 3% of global annual turnover or €15 million for violations.

CFTC

The CFTC on Aug 03, 2026, ordered UBS Financial Services to pay $8 million for failing to supervise the configuration and operation of its AML transaction-monitoring systems for foreign-currency wire transfers.

FINRA

FINRA fined UBS Financial Services $20 million on Aug 03, 2026 for anti-money-laundering violations. The firm failed to establish a compliance program reasonably designed to detect and report suspicious foreign-currency wire transactions.

FDIC

Lineage Bank

Consent Order

The FDIC issued a second consent order against Lineage Bank on June 24, 2026, targeting risks from fintech partnerships and funding concentrations. Lineage Bank is a former partner of bankrupt fintech/BaaS platform Synapse.

RBI

On July 31, 2026, the Reserve Bank of India issued the 'Commercial Banks – Cybersecurity, Technology: Risk, Resilience and Assurance Framework Directions, 2026,' a sector-wide regulatory framework covering cybersecurity governance, incident response, and third-party risk management. The directions apply to all commercial banks and shape how they must manage risks from fintech partners, outsourced technology providers, and other vendors.

Central Bank of Nigeria (CBN)

The Central Bank of Nigeria imposed ₦430 million in fines across 21 penalties on financial institutions in 2025 for delays in resolving customer complaints and failure to comply with CBN directives. The sanctions were disclosed in the CBN's 2025 annual report.

Financial Supervisory Service (FSS)

South Korea's Financial Supervisory Service (FSS) issued new third-party IT risk management guidelines for financial firms using external IT services such as cloud and SaaS. The guidance assigns the board of directors as the ultimate owner of third-party IT risk management.

BaFin

Unknown Sponsor Bank

Regulatory Mandate / Oversight Authority

Germany's BaFin announced it will oversee and enforce compliance around AI usage at banks and insurers, with authority to issue fines. This affects embedded finance and BaaS providers operating under German banking licences that use AI.

FinCEN

US financial institutions (general)

Guidance/Enforcement Suspension

FinCEN announced it will not take supervisory or enforcement action against US financial institutions for certain technical breaches of the Bank Secrecy Act and related regulations when those breaches arise from providing financial services to Venezuela. The commitment took effect July 27, 2026 and runs until January 29, 2027.

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