The financial industry is navigating a whirlwind of regulatory changes, record-breaking activity, and emerging fraud schemes. For compliance officers, auditors, and other stakeholders, staying ahead requires a proactive approach to understanding and addressing these developments. Here, we explore three critical areas shaping the compliance landscape: the surge in regulatory proposals, record-breaking Suspicious Activity Reports (SARs) filings and Automated Clearing House (ACH) payments, and the latest FinCEN advisory on healthcare fraud schemes.
1. A Flood of Regulatory Proposals: A Call to Action
The industry is currently coping with an unprecedented number of regulatory proposals and requests for comment. From the Anti-Money Laundering Act of 2020 (AML) to the GENIUS Act, agencies are seeking input on transformative changes. For example, FinCEN recently proposed fundamentally reforming the requirements for financial institutions’ AML/CFT programs so that they are effective, risk-based, and focused on the greatest threats to financial institutions and national security, directing more resources to higher-risk areas and generating highly useful information for law enforcement. This proposal, alongside others from the OCC, FDIC, and NCUA, underscores the importance of industry feedback.
Despite the perception that small institutions’ voices may go unheard, regulators emphasize the value of comments from all stakeholders. Compliance teams should prioritize reviewing these proposals and submitting thoughtful feedback before deadlines, such as the June 9, 2026 cutoff for several key rules. Engaging in this process not only shapes the regulatory environment but also helps ensure institutions are prepared for upcoming changes.
2. Record-Breaking Year for SAR Filings & ACH Payments
2025 marked a historic year for SARs and ACH payments. U.S. banks, savings institutions, and credit unions filed over two million SARs, contributing to a nationwide total exceeding four million—a nearly 8% increase from 2024. Highly reported activities included suspicious sources of funds and transactions lacking apparent economic purpose. While check fraud has declined, wire transfer fraud and elder financial exploitation are on the rise, signaling areas requiring heightened vigilance.
Simultaneously, ACH payments reached new heights, with 35.2 billion entries totaling $93 trillion in value, which is a 4.9% increase from the previous year. Business-to-business transactions and same-day ACH entries saw significant growth, reflecting the network’s expanding role in financial operations. However, this growth also brings increased fraud risks, particularly in credit push fraud. Institutions must establish robust fraud monitoring systems and provide targeted training to staff in high-risk areas.
3. FinCEN Advisory: Healthcare Fraud Schemes
FinCEN’s latest advisory highlights the growing threat of healthcare fraud schemes targeting Medicare, Medicaid, and state healthcare programs. This nationwide issue involves fraudulent billing, identity theft, and exploitation of government benefits. Compliance teams should familiarize themselves with the advisory’s red flags and incorporate them into training and monitoring programs. For example, unusual billing patterns or discrepancies in patient information may indicate fraudulent activity.
This advisory follows others addressing government benefits fraud and financially motivated extortion, emphasizing the need for institutions to remain vigilant against evolving threats. Leveraging tools like FinCEN’s SAR statistics can help institutions identify regional trends and tailor their training programs accordingly.
How Forvis Mazars Can Help
Amid these challenges, fostering a strong culture of compliance remains paramount. This culture must start at the top, with boards and management setting the tone. A robust compliance management system, supported by targeted risk assessments and clear documentation, is essential for navigating today’s complex regulatory environment.
By staying informed, engaging with regulatory proposals, and proactively addressing emerging risks, financial institutions can not only help ensure compliance but also strengthen their resilience in an ever-changing landscape. Watch our archived webinar, “Compliance Conversations With ProBank Education Services: Q2 2026,” to learn more. Reach out to a professional at Forvis Mazars to learn how ProBank Education Services can help support your organization.