Blog: Compliance

A bank account garnishment is a small transaction with a long tail. The order may be for a few hundred dollars, but the bank sits between three parties with legal rights: the creditor or taxing authority, the customer, and sometimes a co-owner who owes nothing. When processing goes wrong, the bank can end up owing money it never held, repaying funds it froze by mistake, and explaining the failure to its examiners.

This post is for compliance officers, operations managers and risk ...

"Can my bank account be garnished without notice?" is one of the most common questions customers type into a search engine after a freeze, and one of the most common questions they ask a branch employee. The honest answer is that customers often do not receive advance notice of the freeze itself. But that does not mean nobody owes them a notice. Once the bank acts on an order, the bank frequently has its own notice obligations, with short deadlines, under federal and state law.

This ...

The CTR exemption system exists so that banks do not spend their days reporting the cash deposits of the grocery chain down the street, the county treasurer's office and the regional hospital system's parking operation. Those reports carry almost no value for law enforcement, and the regulation lets a bank stop filing them if it follows a defined process. Many banks still do not use it, or use it badly, and both choices cost something. Unused exemptions mean thousands of low-value CTRs.

SAR reporting requirements for banks come from two sets of rules that overlap: FinCEN's bank rule at 31 CFR 1020.320 and the SAR rule of each federal banking agency. Read together, they answer four questions every BSA officer has to get right: when a suspicious activity report should be filed, how much activity it takes, how long the bank has, and what happens when the activity keeps going.

This guide sets out the requirements as they stand, including the October 2025 FAQs from ...

The new-account exception is the broadest hold authority in Regulation CC. For the first 30 days of an account's life, most of the availability schedule simply does not apply to ordinary checks, there is no regulatory maximum on how long they can be held, and no per-hold notice is required. That is a lot of latitude, and it exists for a good reason: a bank knows almost nothing about a brand-new depositor, and new accounts are where a large share of check fraud lands.

The latitude is ...

When a customer who receives Social Security dies, the benefit deposits do not stop right away. The payment arriving the month after death has to go back, and often one or two more arrive before the agency's records catch up. By the time Treasury asks for the money, a surviving spouse or adult child may have spent it. The federal rule for who pays in that case is 31 CFR Part 210, Subpart B, and it puts the bank in the middle. A bank that knows the rules and answers a reclamation notice ...

Ask ten bankers which training is legally required and you will get ten different lists, most of them too long. Annual fair lending training, UDAAP training, elder abuse training, OFAC training, Reg CC training: all of them are common, most are wise, and examiners will ask about several. But only a handful of training obligations are actually written into regulation, and the ones that are rarely say "annual."

The difference matters. A training program built on "everything is ...

Training is the BSA/AML pillar most banks believe they have covered and most often cannot prove. The sessions happened. The online modules were assigned. But when an examiner asks which lenders completed training on lending-related red flags, what the board was taught and when, or what happened to the six employees who never finished, the answers live in three systems and two people's memories.

This post covers what the rules actually require for Bank Secrecy Act training, who must ...