Edition 18 · Thursday, October 1, 2026
What’s new in compliance. Why it matters. What it means for your operations.
In This Edition
A Bank CEO Gets 112 Months for Fraud and Sanctions Dealings
From the Founder
Bank failures now come with prison terms for the people who ran them. A CEO who screens customers but exempts himself is a gap no customer file catches. Boards should ask their compliance officer this quarter whether directors and officers sit in the sanctions screening file. If the answer is no, that is the finding.
Dominic Suszek · Founder and CEO, Global RADAR
30-Second Read
- Nodus Bank’s former CEO gets 112 months for fraud and Venezuela sanctions dealings
- Cuba Sanctions Regulations now in force; banks must close certain private entrepreneur accounts
- FATF plenary opens October 26; UK licence and Cuba wind-down clocks expire that week
1. Top story of the week
A bank CEO just got 112 months for looting his own bank and dealing with a sanctioned oil figure. On September 21, Tomás Niembro Concha, former CEO of Nodus International Bank in Puerto Rico, was sentenced for wire fraud and IEEPA conspiracy. He diverted at least $24.9 million from 2017 to 2023, hid it from the board and regulators, and closed a $4 million property deal with a Venezuela-related SDN. Nodus failed in 2023.
Why This Matters
Regulators were misled for six years while the bank’s own CEO self-dealt and touched an SDN. Board oversight, insider lending and sanctions screening failed together, and prosecutors charged the executive.
Operational Implications
Three steps for this week:
- Run every director, officer and affiliate through your sanctions screening today and on each SDN update; most stacks screen customers only.
- Build a related-party and insider-loan register for your audit committee to review by October 31.
- Tell your board chair this case is the standard examiners will cite; independent testing of executive conduct is not optional.
2. Enforcement and penalties
- OFAC, September 29: About 22 Sinaloa Cartel figures and 30 front entities, including real estate and restaurant firms, added to the SDN List.
- DOJ, September 15: Alex Saab, a Maduro associate, pleaded guilty to money laundering tied to bribery and procurement fraud.
- OFAC, September 28: Venezuela General Licenses 46E, 48D and 49B reissued in amended form; confirm which version your approvals cite.
Why This Matters
Cartel fronts now look like ordinary real estate, restaurant and financial services customers at onboarding. Prosecutors also pursue the money side of bribery and Venezuela cases, not only the predicate crime.
Operational Implications
Three steps by October 7:
- Screen your commercial real estate, restaurant and money services customers against the September 29 Sinaloa additions today and document the result in the case file.
- Update the Venezuela license matrix to GL 46E, 48D and 49B; an approval citing a superseded version is a control gap, so brief the trade desk this week.
- Escalate customers with Saab, Sinaloa or Venezuelan procurement links to your compliance officer; one SAR too many beats explaining a miss.
3. New guidance and rulemaking
- OFAC, effective September 25: Final Sanctions Penalties Regulations (31 CFR part 505) consolidate penalty and procedure rules with no substantive changes.
- OFAC, effective September 30: Cuba Sanctions Regulations bar Restricted List dealings, end U-Turn transactions, and require closing Cuban private entrepreneur accounts.
Why This Matters
The Cuba rules make closing Cuban private entrepreneur accounts a bank obligation, so this is an exit and blocking workflow, not a screening hit. The penalties regulation changes no numbers but centralizes where examiners will look.
Operational Implications
Two steps by October 15:
- Query core banking today for accounts held by Cuban independent private entrepreneurs, block the funds, and route access requests to OFAC licensing.
- Rewrite the Cuba section of your sanctions policy to cite 31 CFR part 516 and drop U-Turn handling; a policy citing only the old regulations will not survive an exam.
Theme of the Week
Nodus failed after its CEO self-dealt $24.9 million and traded with a Venezuela-related SDN; the sentence was 112 months. Insider conflict monitoring and sanctions screening are run by different teams and rarely compared. Institutions that screen customers but not directors, officers and related parties have a structural blind spot examiners will test.
4. Global watch
- EU Council, September 22: Russia asset freezes renewed to 2029; Usmanov and Fridman delisted.
- Australia, September 23: 106 new Russia designations, including shadow fleet vessels and entities.
- FINTRAC, September 24: Published credit union penalties up to CAD 676,500 for policy failures.
- AMLA, September 27: Consultations on reporting and risk-profile standards closed; final drafts due November 30.
5. Coming up in the next 30 days
| Date |
Event or deadline |
| October 1, 2026 |
FinCEN Banque Misr UAE Section 311 proposal comment period closes. |
| October 19, 2026 |
Comments close on Treasury’s GENIUS Act stablecoin issuance, offer and sale rulemaking. |
| October 22, 2026 |
UK Iran Interim Basic Necessities General Licence expires; OFSI will not renew it. |
| October 25, 2026 |
EU 21st package wind-down ends for pre-existing contracts on newly listed goods. |
| October 26 to 30, 2026 |
FATF Plenary and working groups meet in Paris; watch grey list outcomes. |
| October 30, 2026 |
Cuba wind-down ends for group educational travel and professional meetings. |
Next Wednesday
Next Wednesday: first bank reactions to the Cuba account-closure rule and the October 1 Banque Misr comment close, with FATF’s plenary three weeks out.
Want a 30-minute review of director, officer and related-party screening, the gap in the Nodus Bank case, against your current sanctions program? Book a call with a Global RADAR compliance specialist.
Best regards,
Dominic Suszek
Founder and CEO, Global RADAR
globalradar.com
