FinCEN commits to no BSA supervisory or enforcement action over authorised financial services in Venezuela until 29 January 2027

On 27 July 2026 the Financial Crimes Enforcement Network issued a statement of enforcement policy committing not to take any supervisory action — including citing a violation of law — or pursue any enforcement action against any US financial institution under Bank Secrecy Act requirements as a result of providing authorised financial services in Venezuela. The commitment covers services provided from 27 July 2026 through 29 January 2027, and was issued in consultation with the Internal Revenue Service and the staffs of the Federal Reserve Board, the FDIC, the National Credit Union Administration and the OCC. An institution may rely on it only if it currently meets an applicable BSA compliance programme requirement and continues reasonable efforts to comply; has not been the subject of a final enforcement action by FinCEN or its primary federal regulator in the prior 24 months involving BSA or similar requirements; and remains compliant with applicable OFAC-administered sanctions regulations and authorisations. FinCEN states the intent is that institutions exercising reasonable care are not penalised for anything other than knowing, willful or intentional violations.

This is not an enforcement action and not a change to the sanctions. It is a declared supervisory posture, addressed to no named institution: the BSA obligations remain in force, and what has been set aside for six months is the supervisory and enforcement exposure attached to them in one jurisdiction. The document creates no authorisation to transact, and FinCEN states the commitment reaches no statutes or regulations beyond those it addresses.

The two OFAC licences the statement sits alongside establish what "authorised financial services" reaches. General License 57, issued 14 April 2026, authorises financial services to, from or for the benefit of Banco Central de Venezuela, Banco de Venezuela, Banco Digital de los Trabajadores and Banco del Tesoro, and defines financial services to include US dollar correspondent account services, wire and ACH transfers, money transfer services, remittance collection and forwarding, payment cards and digital wallets. General License 60, issued 25 June 2026, authorises earthquake-relief transactions through 23 October 2026, including processing funds on behalf of third-country persons. Note 3 to GL 57 expressly preserved BSA, USA PATRIOT Act and FinCEN obligations; the July statement is what softens the supervisory consequence of that carve-out.

Two things remain open, and both are the desk's observation rather than anything the documents settle. The windows do not align: GL 60's authorisation lapses on 23 October 2026, while FinCEN's commitment runs three months longer, to 29 January 2027, and GL 57 carries no expiry on its face. And whether an equivalent BSA enforcement-policy statement exists, or is contemplated, for any other sanctioned jurisdiction is not established by these documents.