De Novo, BSA/AML & High-Risk Banking: What Fintechs and Institutions Must Know

What Happened

According to Cogent Law Webinars on September 9, 2026 in Federal — U.S., Mark Dabertin and Chris Van Dyck of Cogent Law on de novo bank formation, BSA/AML program design, and what fintechs and financial institutions must know before entering high-risk banking. The primary source is linked in the Source section below; readers are encouraged to review it directly for full context.

Why This Is Trending Now

Fintechs are increasingly seeking de novo charters to gain direct access to payment systems and reduce reliance on sponsor banks.

Why Businesses Should Pay Attention

Understanding the regulatory hurdles and compliance requirements is critical for any fintech considering a bank charter.

Practical Considerations

Businesses may want to monitor the status of the underlying rule, filing, proceeding, or announcement as it evolves. Companies may need to evaluate how this development could interact with current contracts, licenses, disclosures, and compliance programs. The issue may raise questions around vendor obligations, reporting timelines, and internal policy updates that warrant discussion with qualified counsel.

Cogent Law Perspective

Cogent Law helps fintechs navigate the complex process of bank formation and compliance program design. The best next step is to speak with counsel about the facts specific to your organization.

Key Takeaways

• Fintechs are increasingly seeking de novo charters to gain direct access to payment systems and reduce reliance on sponsor banks.
• Understanding the regulatory hurdles and compliance requirements is critical for any fintech considering a bank charter.
• Cogent Law helps fintechs navigate the complex process of bank formation and compliance program design.
• Review the primary source from Cogent Law Webinars for the full record before making any decisions.
• Speak with Cogent Law to discuss how this development may affect your business.

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