Product Updates June 2026

The Product Updates for June 2026 from BankPolicies.com feature the following revised policy template products:

BSA Suspicious Activity Report Notices Template

The update to this product is in response to:

• FinCEN Notice FIN-2026-NTC1 entitled “FinCEN Notice on the Threat of Human Trafficking During the 2026 FIFA World Cup” dated 05/11/26 that urges financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity connected to human trafficking associated with the 2026 Fédération Internationale de Football Association (FIFA) World Cup.

• FinCEN Alert FIN-2026-Alert002 entitled “FinCEN Alert on the Use of Front Companies, Financial Facilitators, and Digital Asset Infrastructure by Iran’s Islamic Revolutionary Guard Corps to Evade Sanctions and Launder Proceeds” dated 05/11/26 to assist financial institutions in identifying actors suspected of funding and facilitating procurement networks supporting the Islamic Revolutionary Guard Corps (IRGC) and mitigating those risks through the filing of suspicious activity reports (SARs).
• FinCEN Advisory FIN-2026-A002 entitled “Joint Advisory on Non-Work Authorized Populations and Their Employers and Risks to the Integrity of the U.S. Financial System” dated 06/05/26 that advises financial institutions (in particular, banks) to be vigilant against fraud schemes and other suspicious or potentially criminal activities involving the unlawful employment of illegal aliens and the associated risks to the integrity of the U.S. financial system.  Through these schemes, employers can gain an unfair advantage over legitimate U.S. businesses; depress wages; facilitate identity theft of people who are authorized to work in the United States, including American citizens; and steal millions of dollars in federal and state payroll tax revenue meant for government benefit programs.  Non-work authorized populations and their employers often rely on access to the U.S. financial system.  In certain instances, the access to financial services and unlawfully obtained wages can be leveraged to facilitate the financing of transnational criminal organizations “TCOs” (several of which have been designated as Foreign Terrorist Organizations “FTOs”) and their global criminal enterprises, including drug trafficking, human trafficking, and other illegal activity in the United States.

Commercial Loan Policy Template

Small Business Administration Loan Policy Template

The update to these products is in response to the SBA’s New Release 26-52 entitled “SBA Doubles Cumulative 7(a) and 504 Loan Limit to $10 Million” dated 05/18/26 that announced a new rule that will allow eligible borrowers to combine their 7(a) and 504 loans for up to $10 million in SBA-backed financing, increasing the cumulative loan limit from its current $5 million and expanding the capital available to small businesses across all industries.  Small manufacturers, who can currently secure an unlimited number of 504 loans as long as each loan is tied to a distinct project, will also be able to apply for $5 million through the 7(a) loan program.  Effective July 4, 2026, this rule will raise the SBA’s maximum financing offering to small businesses to the highest level in agency history.

Commercial Real Estate Loan Policy Template

The update to this product is in response to OCC Bulletin 2026-20 entitled “Real Estate Lending Escrow Accounts: Final Rule” dated 05/15/26 that announced a final rule to codify longstanding powers of national banks and federal savings associations to establish or maintain real estate lending escrow accounts and to exercise flexibility in making business judgments as to the terms and conditions of such accounts, including whether and to what extent to offer any compensation or to assess any fees related thereto.

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