FinCEN Issues Exceptive Relief on a Bank Secrecy Act Requirement for Credit Unions

Alexandria, VA (February 17, 2026) ― Last week, the Financial Crimes Enforcement Network (FinCEN) announced a new Bank Secrecy Act regulatory relief opportunity regarding the Customer Due Diligence regulation.¹

On February 13, 2026, FinCEN issued an Exceptive Order that removed the regulatory requirement for credit unions to identify and verify information for business customers each time the business customer opens a new account. Pursuant to FinCEN's order, credit unions may limit identification and verification of these customers to the following circumstances:

• When a legal entity customer (business) first opens an account,
• Any time afterwards when the financial institution has knowledge of facts that would reasonably call into question the reliability of beneficial ownership information previously obtained, and
• As needed based on the financial institution's own risk-based procedures for conducting ongoing due diligence.

This exceptive relief is optional, and credit unions are not required to use it. Credit unions must continue to comply with all anti-money laundering/countering the financing of terrorism requirements under the Bank Secrecy Act and its implementing regulations.

For additional information, please see FinCEN's Announcement on Exceptive Relief for Customer Due Diligence. If you have any questions about the order, please contact FinCEN's Regulatory Support Section by submitting an inquiry at www.fincen.gov/contact, or contact your examiner.