Compilation of BSA/AML Enforcement Actions Against Fintech Sponsor Banks and BaaS Institutions (2022–2025)
Between 2022 and 2025, federal and state banking regulators issued a wave of enforcement actions against banks that had built Banking-as-a-Service (BaaS) businesses (sponsoring fintech companies to offer deposit accounts, prepaid cards, and payment services to end consumers).
Those enforcement actions are publicly available. But they're scattered across the FDIC, OCC, Federal Reserve, and various state regulator department websites — published one at a time, in inconsistent formats, with no single place to find them all.
I made a best effort at trying to compile all of them into one document.
The result is a 340-page PDF containing:
All 15 public enforcement orders from August 2022 through April 2025
A cover page and table of contents with key metadata for each action: regulator, date, action type, penalty amounts, termination status, key fintechs named, and primary findings
A chronological enforcement timeline showing the peak under the Biden administration and the sharp dropoff after January 2025
The full text of every order, unmodified
This compilation can be useful for:
BSA/AML compliance research and benchmarking
Understanding how regulators have approached third-party fintech risk oversight
Tracking the evolution of BaaS enforcement trends across administrations
Feeding into an LLM to analyze patterns, compare remediation requirements, or identify common deficiencies across orders
This compilation is a research and reference resource only. All documents are reproductions of publicly available regulatory enforcement actions. Nothing here represents the views of any regulator or of the institutions named, any of current or prior employers. It’s just a condensed summary of publicly available data.