FinCEN Eases BSA Requirements for Venezuela Recovery Transactions

The Financial Crimes Enforcement Network has announced temporary enforcement discretion for certain Bank Secrecy Act (BSA) requirements to support financial institutions processing authorized transactions related to Venezuela’s economic recovery and earthquake relief efforts.

Effective July 27, 2026, through January 29, 2027, the policy applies to financial services authorized under the Office of Foreign Assets Control’s General Licenses 57 and 60. The measure is intended to facilitate legitimate humanitarian assistance and recovery-related financial activity without weakening core anti-money laundering (AML) and sanctions controls.

Under the policy, FinCEN will exercise temporary enforcement discretion for qualifying institutions that are making reasonable efforts to comply with applicable BSA requirements while supporting authorized transactions. However, the agency emphasized that the measure does not suspend AML or sanctions obligations, nor does it exempt institutions from maintaining effective AML compliance programs.

To qualify for the relief, financial institutions must maintain effective AML controls, continue complying with OFAC sanctions regulations, make reasonable efforts to meet applicable BSA requirements, and have no recent significant BSA enforcement actions. FinCEN also clarified that the policy does not shield institutions from supervisory or enforcement action involving knowing, willful, or intentional violations of the BSA or other applicable laws.

The announcement reflects a risk-based regulatory approach that seeks to balance humanitarian and economic recovery objectives with the continued protection of the financial system from money laundering, sanctions evasion, and other illicit finance risks.

Why It Matters for Compliance

The policy provides temporary regulatory flexibility for qualifying institutions, but it does not reduce core compliance expectations. Financial institutions facilitating authorized Venezuela-related transactions must continue applying robust AML controls, sanctions screening, and customer due diligence while documenting reasonable compliance efforts.