Fintech · Industry brief

OFAC enforcement actions against financial services firms intensified in 2024–2025 with record penalties. Interactive Brokers LLC faced a $11.83 million penalty for servicing clients in sanctioned jurisdictions, while GVA Capital received a $215.99 million penalty for managing U.S. investments linked to a sanctioned Russian oligarch and failing to comply with an OFAC subpoena. Additional fintech-adjacent enforcement included Unicat Catalyst Technologies ($3.88 million for Iran and Venezuela sanctions violations) and Harman International Industries ($1.45 million for Iran violations). OFAC's 2024–2025 enforcement priorities expanded beyond traditional finance to include technology, cryptocurrency platforms, and venture funds, with penalties adjusted to $330,947 per civil violation under IEEPA. The regulatory landscape shifted with removal of Syria Sanctions Regulations and new general licenses for Russia-related sanctions, requiring organizations to maintain agile compliance systems capable of real-time updates.

Federal Reserve Vice Chair Michelle Bowman emphasized that effective bank supervision requires timely action by examiners to address vulnerabilities as they emerge, citing lessons from Silicon Valley Bank's failure. The Fed is restructuring its supervision function to improve decision-making by clarifying responsibility and authority between the Federal Reserve Board and Reserve Banks, and establishing direct escalation channels from examination teams to senior leadership. The FDIC and OCC are implementing the GENIUS Act with parallel rulemakings on stablecoins, including guidance on permissible activities for stablecoin issuers, reserve assets, and tokenized deposits. The OCC's final rule is expected before the end of October. The FDIC is also updating confidentiality rules for supervisory information to allow banks greater flexibility in sharing information with affiliates, service providers, and M&A participants without prior regulatory approval, while maintaining a principles-based framework rather than prescriptive requirements.