Compliance Goals for 2026: Five Priorities Every Community Bank and Fintech Should Set Now

As 2026 approaches, many compliance teams are feeling the squeeze from all sides. Regulatory expectations continue to evolve, partner banks are asking deeper questions, products and features are changing faster than ever – and resources haven’t exactly grown to match. It’s easy to spend the year reacting to exam findings, audit issues, and urgent partner requests instead of executing a clear, proactive plan.

That’s where deliberate goal-setting becomes critical. A well-defined set of compliance priorities for 2026 does more than organize your to-do list – it gives your board, senior management, and partner banks confidence that you understand your risk profile and are steering the program accordingly. It also helps your team say “not now” to low-value work so you can focus on the initiatives that actually move the needle.

In this article, we outline five practical compliance goals for 2026 that every community bank and fintech should consider. These aren’t theoretical ideals; they’re concrete focus areas that align with examiner expectations, partner bank standards, and what we see day-to-day working with institutions like yours.

Goal #1: Strengthen the Compliance Management System (CMS) Foundation

Before you set ambitious goals for 2026, it’s worth asking a simple question: How strong is your CMS, really?

For both community banks and fintechs, the CMS is the backbone of the entire compliance program. It’s how you demonstrate to regulators, partner banks, investors, and your own board that compliance isn’t just a policy binder – it’s a managed, monitored, and accountable function within the organization. When the CMS is weak or fragmented, everything else (BSA/AML, fair lending, marketing, third-party risk) becomes harder to defend.

A solid 2026 strategy starts with reinforcing four core pillars: governance, policies and procedures, monitoring and testing, and complaint management.

Get Governance and Oversight Out of “Implicit Mode”

A lot of institutions think their governance structure is clear because “everyone knows” who owns what. Examiners and partner banks, however, care less about what’s understood informally and more about what’s documented and consistently followed. For 2026, focus on:

• Clearly defined roles and responsibilities
  • Board and Board committees (or equivalent for fintechs) receiving regular, substantive compliance reporting.
  • Senior management and business line leaders with documented accountability for compliance within their areas.
  • A designated Compliance Officer or Compliance function with authority, independence, and direct reporting lines.
• Regular reporting cadence
  • Quarterly (or more frequent) reports that go beyond activity counts to include trends, issues, emerging risks, and remediation status.
  • Evidence that the Board or committee reviews and discusses compliance reports, not just receives them.

The goal for 2026 is to move from ad hoc updates to a predictable, repeatable governance rhythm that stands up to examiner and partner bank scrutiny.

Align Policies and Procedures With Reality

Another common pain point: policies and procedures that don’t match what’s actually happening in the business. That disconnect is one of the first things examiners and partners notice. Use 2026 to:

• Inventory and rationalize policies and procedures
  • Ensure each key regulation, risk area, and product has a current, version-controlled policy and related procedures.
  • Remove duplicate or outdated documents that cause confusion.
• Test “policy vs. practice” alignment
  • Ask: If we pulled a sample of accounts, marketing materials, or transactions, would the steps taken match what our procedures say?
  • Where there’s a gap, either correct the practice or update the documentation—but don’t leave it misaligned.
• Tie documents to owners and review cycles
  • Each policy/procedure should have a named owner and a planned review date (at least annually or when material changes occur).

Formalize Monitoring, Testing, and Complaint Management

A CMS is only as strong as its ability to detect and correct issues before they become findings or enforcement actions. That’s where monitoring, testing, and complaint management come in. For 2026, consider:

• A documented compliance monitoring plan
  • Risk-based: higher-risk areas are tested more frequently; emerging risks are added as needed.
  • Specific: includes scope, frequency, sampling approach, and who performs the work.
  • Evidence-based: workpapers, testing results, and issue logs are retained and easy to access.
• Clear issue management and remediation
  • Findings and observations captured in a central log.
  • Assigned owners, due dates, and status tracking.
  • Follow-up to confirm that corrective actions were implemented and effective.
• Complaint management as an early-warning system
  • Centralized intake (including partner channels), categorization, and escalation.
  • Regular analysis to identify trends, root causes, and potential UDAAP or fair lending concerns.
  • Feedback loop into training, product changes, and monitoring.

The 2026 objective is to move from reactive problem-solving to a structured detect–escalate–remediate cycle that demonstrates control over your compliance risk.

2026 Action Steps for Goal #1

To make this goal actionable, consider building these into your 2026 plan:

• Conduct a CMS “health check” in Q1 to identify gaps in governance, documentation, monitoring, and complaints.
• Map key laws, regulations, and risk areas to owners, policies, procedures, and monitoring activities.
• Approve a 2026 compliance monitoring schedule and track completion throughout the year.
• Enhance Board/committee reporting to include metrics, trends, and status of open issues – not just a narrative summary.

 

Goal #2: Modernize Your BSA/AML & Sanctions Programs

If there’s one area that never falls off the regulatory radar, it’s BSA/AML and sanctions. For community banks, credit unions, and fintechs alike, expectations keep rising – especially around risk assessments, model governance, sanctions screening, and documentation. At the same time, products, partners, and geographies are changing faster than many programs are being updated.

That’s why modernizing your BSA/AML and sanctions program should be a core 2026 goal. This isn’t about ripping everything out and starting over; it’s about making sure your program actually reflects how your business operates today – and can stand up to examiner, law enforcement, and partner bank scrutiny.

Make Your BSA/AML & Sanctions Risk Assessment a Living Document

Too many institutions treat the BSA/AML/OFAC risk assessment as a static, once-a-year exercise that doesn’t fully capture what’s changed in the last 12–18 months. In 2026, aim to turn it into a living, decision-driving tool.

• Aligning products, services, and channels with current risk
  • If you’ve introduced new digital onboarding flows, instant-payment rails, or higher-risk products (e.g., cross-border, crypto-adjacent, cash-intensive segments), your risk assessment should clearly reflect that.
• Capturing customer and geographic risk realistically
  • Incorporate updated customer demographics, occupation/industry profiles, and geographic exposure (domestic and international).
• Linking risk assessment to controls and monitoring
  • For each higher-risk area, explicitly tie the risk to specific mitigating controls: CDD/EDD steps, transaction monitoring rules, sanctions screening processes, and manual reviews.

The goal: when examiners or partner banks ask “Why is this rated moderate instead of high?” you can point to a clear, documented rationale and the controls that support it.

Tighten Model, System, and Rule Governance

Whether you’re using an in-house system, vendor platform, or partner bank solution, model and rule governance are under the microscope. Regulators expect you to understand how your tools work—not just that they’re “industry standard.” In 2026, prioritize:

• Documented model and system inventory
  • Maintain a list of all BSA/AML and sanctions models, rules engines, and tools (name-screening, transaction monitoring, behavioral analytics, etc.).
• Clear ownership and change control
  • Define who is responsible for parameter settings, threshold changes, tuning, and periodic reviews.
  • Implement a change management process that documents why rules were added, removed, or adjusted – and how effectiveness was evaluated.
• Independent validation or review
  • Periodically validate that models and rules are reasonably calibrated to your risk profile (not too many false positives, not missing obvious activity).
  • Document methodology, data used, limitations, and remediation steps if weaknesses are identified.

Formalize CDD/EDD and Ongoing Monitoring

CDD and EDD are often where programs drift over time – especially as onboarding flows are streamlined, partnerships evolve, or new customer segments are added. In 2026, aim to make your CDD/EDD processes consistent, documented, and repeatable.

• Standardized CDD at onboarding
  • Clear requirements for identity verification, beneficial ownership (where applicable), source of funds, expected activity, and customer risk scoring.
  • Tailored procedures by customer type (retail vs. business; domestic vs. international; higher-risk industries).
• Risk-based EDD
  • Defined triggers for EDD (high-risk geographies, industries, products, ownership structures, negative news, sanctions proximity, etc.).
  • Additional information and documentation requirements for high-risk customers, with periodic reviews built in.
• Ongoing and event-driven reviews
  • Triggers for updating customer risk (e.g., major changes in activity, negative media, law enforcement inquiries, changes in ownership or control).
  • Documented periodic review cadence for high-risk customers (e.g., annually), including steps to be re-performed and evidence to be retained.

The goal is to demonstrate that customer risk is understood at onboarding and re-evaluated as risks change, not just at account opening.

Upgrade Sanctions Screening and Escalation Processes

Sanctions expectations have expanded beyond simple name-checking. In 2026, sanctions programs should be comprehensive, risk-based, and well-documented.

• Screening coverage and configuration
  • Ensuring you are screening:
    • Customers and beneficial owners
    • Counterparties (where applicable)
    • Transactions and payments (especially cross-border)
  • Confirming your lists, settings, and matching logic are appropriate for your risk profile.
• Tiered alert handling and escalation
  • Documented criteria for true hits vs. false positives.
  • Clear ownership for investigations, with timelines and documentation standards.
  • Defined escalation paths to BSA Officer/Compliance Officer and, where applicable, to the Partner Bank.
• Reporting and documentation
  • Procedures for blocking, rejecting, or freezing transactions and accounts when required.
  • Clear guidance for when to file reports with regulators or notify law enforcement.
  • Centralized storage of case files, decisions, and any regulatory reporting.

2026 Action Steps for Goal #2

To turn modernization into a concrete plan, consider embedding these steps into your 2026 roadmap:

• Q1–Q2: Refresh the BSA/AML/OFAC risk assessment
  • Incorporate any new products, geographies, partners, and customer segments.
  • Explicitly link risks to controls and monitoring activities.
• Schedule an independent BSA/AML & sanctions review or model validation
  • Use the results to prioritize tuning, documentation updates, and process enhancements.
• Document and standardize CDD/EDD workflows
  • Create or refine procedure documents, checklists, and system requirements for onboarding, periodic reviews, and event-driven reviews.
• Enhance sanctions processes and documentation
  • Review screening coverage, alert workflows, and escalation paths.

Update procedures to ensure consistent handling and clear regulatory reporting triggers

Goal #3: Elevate Consumer Protection, UDAAP & Fair Lending Oversight

If the last few years have made anything clear, it’s this: consumer protection is not a “nice to have” side piece of compliance. It’s where regulators, plaintiff’s attorneys, and the media all converge. For digital-first institutions and fintech partnerships, risks are amplified by speed, automation, and scale.

In 2026, one of your core goals should be to move beyond “we don’t think we’re doing anything unfair” and toward a structured, documented consumer protection and fair lending framework—especially across marketing, product design, servicing, and complaints.

Build a Real Marketing & Advertising Review Framework

Marketing is often where UDAAP risk shows up first: teaser rates, “no fee” claims, how benefits and limitations are described, and what is not said in the fine print. For fintechs and banks co-branding products, the risk is multiplied by multiple teams touching content.  In 2026, aim for a marketing program that is formal, repeatable, and documented:

• Create a standardized marketing review process
  • Require compliance/legal review for campaigns that reference pricing, fees, APR/APY, rewards, or “no cost/no fee” claims.
  • Use checklists that tie back to specific regulations (Reg Z, Reg DD, Reg E, TISA, etc.) and UDAAP considerations.
• Clarify who owns what
  • Marketing owns messaging and creative.
  • Compliance owns regulatory and UDAAP review.
  • Product/operations confirm that the offer can actually be delivered as described.
• Document approvals and changes
  • Track versions, approvers, and conditions (e.g., “valid until X date,” “only for Y segment”).
  • Keep a central repository of final, approved content – what you can show to examiners and partner banks.

The goal: no more “We think someone reviewed that email campaign last year.” Instead, you can show who reviewed it, when, and against what criteria.

Treat Customer Communications as Part of the Product

Disclosures, FAQs, in-app messages, and website copy all shape how consumers understand your products. If what’s on the screen doesn’t match how the product actually behaves, you’ve just created UDAAP and fair lending risk.  For 2026, focus on making communications accurate, consistent, and understandable:

• Align disclosures with actual product behavior
  • Ensure terms and conditions, fee schedules, and product pages are synced whenever a feature or price changes.
  • Double-check grace periods, availability of funds, dispute timelines, rewards rules, and promotional offers.
• Review high-impact touchpoints
  • Account opening flows, adverse action notices, dispute/billing error communications, change-in-terms notices, and collections/recovery messaging.
  • Anywhere a consumer’s expectations about risk, cost, or outcome could be set – or mis-set.
• Test for clarity and comprehension
  • Avoid jargon where possible; explain complex concepts with examples.
  • Pay special attention to vulnerable or less sophisticated consumer segments where confusion is more likely.

The objective is to ensure that a reasonable consumer would understand what they’re signing up for, what it costs, and how it works—and that you can show regulators you tested for that.

Make Fair Lending and Product Design Part of the Conversation Up Front

Fair lending isn’t just about underwriting and pricing models; it’s also about who you market to, how you design products, and how you handle exceptions.

In 2026, you don’t need a full-blown econometric study to show you’re paying attention, but you do need a basic, risk-based fair lending framework:

• Risk-based fair lending review
  • Identify which products and channels carry the most fair lending risk (e.g., unsecured credit, buy now/pay later, indirect lending, certain marketing partnerships).
  • Perform periodic reviews of decisioning, pricing, offers, and exceptions in those areas.
• Monitor exceptions and overrides
  • Track when frontline staff or automated systems deviate from standard pricing or credit policies.
  • Review patterns by branch, officer, channel, and customer segment to identify potential disparate treatment.
• Bring fair lending into product and marketing discussions
  • Include compliance in new product development and marketing strategy meetings early, not after the campaign is designed.
  • Ask: Who is most likely to benefit from this product or offer – and who might be left out?

Turn Complaint Data into a Consumer Protection Radar

Complaints are one of the best (and cheapest) sources of UDAAP and fair lending intel—but only if you do more than log and close them. For 2026, treat complaints as a risk signal, not just a service metric:

• Centralize complaint intake and categorization
  • Pull complaints from all sources: direct channels, partner banks, app stores, social media (where feasible), and regulators.
  • Categorize by product, issue, root cause, and severity.
• Analyze trends regularly
  • Look for spikes by product, channel, partner, or customer segment.
  • Flag repeat themes tied to disclosures, fees, servicing issues, or perceived unfair treatment.
• Feed insights back into the program
  • Use complaint themes to drive updates to scripts, training, product features, and monitoring/testing plans.
  • Escalate high-risk themes (UDAAP, discrimination, vulnerable populations) to the Compliance Committee or Board.

2026 Action Steps for Goal #3

To make this goal real, consider these concrete steps for your 2026 plan:

• Build or refine a marketing/communications review process
  • Implement checklists, workflows, and documentation standards for campaign and disclosure review.
• Complete a targeted consumer protection/UDAAP gap analysis
  • Review high-risk products and communications; identify where expectations, fees, or terms may be unclear or potentially misleading.
• Plan at least one focused fair lending or consumer protection review

Prioritize a high-risk product or channel; document scope, methodology, and results.

Goal #4: Tighten Third-Party & Fintech Partner Risk Management

For many community banks and fintechs, the riskiest activities don’t always live inside their own walls—they live with vendors and partners. Core processors, ACH/payment providers, KYC/KYB vendors, cloud service providers, marketing affiliates, and fintech program managers all introduce operational, compliance, and reputational risk.

Regulators have been very clear: you can outsource activities, but not responsibility. Partner banks are expected to fully understand and oversee their fintech programs, and fintechs are expected to be exam-ready when their bank or regulators come calling.

In 2026, tightening third-party and fintech partner risk management should be a core goal, with a focus on risk-tiering, due diligence, ongoing monitoring, and clearly documented roles.

Get Clarity on Who Your “Third Parties” Actually Are

You can’t manage what you can’t see. Many institutions underestimate how many third parties they rely on—or how critical some of them are.

• Refresh your vendor/partner inventory
  • Include traditional vendors (core, LOS, collections), cloud/SaaS providers, data aggregators, and specialist fintech partners.
  • Don’t forget “embedded” vendors used by other teams (IT, marketing, HR, customer service tools).
• Define “critical” and “high-risk” relationships
  • Critical: those whose failure would significantly disrupt operations, customer service, or compliance.
  • High-risk: those that touch customer funds, NPPI, sanctions, KYC/KYB, onboarding, or ongoing servicing.

Risk-Tier Your Vendors & Partners and Match Due Diligence to Risk

Not every vendor needs the same level of scrutiny – but high-risk and critical partners absolutely do. In 2026, focus on right-sizing your oversight.

• Clear risk-tiering criteria
  • Factors like data sensitivity, access to funds, regulatory impact, business continuity impact, and geographic/OFAC risk.
  • Simple scoring is fine as long as it’s consistent and documented.
• Risk-based due diligence expectations
  • For critical/high-risk vendors and fintech partners:
    • Information security questionnaires, SOC reports, penetration testing summaries, business continuity/DR plans.
    • Compliance program documentation (BSA/AML, sanctions, UDAAP, privacy, complaint handling).
    • Licensing, registrations, and any enforcement or regulatory actions.
  • For lower-risk vendors:
    • Streamlined information requests that still address key risks without over-engineering the process.
  • Pre-engagement vs. ongoing
    • Due diligence before signing contracts or launching programs.
    • Periodic reviews based on risk tier (e.g., annual for critical, every 2–3 years for lower risk).

The objective is a defensible framework: you can explain why Vendor A gets a deeper review than Vendor B, and how that aligns with risk.

Strengthen Contracts, SLAs & Shared Compliance Responsibilities

Even the best due diligence falls flat if the contract doesn’t reflect it. In 2026, aim to ensure your agreements actually support your oversight obligations.

• Embedding compliance expectations in contracts
  • Requirements to maintain a compliance program consistent with applicable laws and partner bank obligations.
  • Data protection standards, breach notification timeframes, and cooperation expectations.
• Audit and access rights
  • Rights to receive key reports (SOC, penetration tests, exam findings where appropriate).
  • Rights to conduct or commission audits/reviews, especially for critical or high-risk relationships.
• Service levels and remediation
  • SLAs that address system uptime, response times, incident handling, and customer impact.
  • Clear expectations for corrective actions and timelines when issues are identified.

Make Ongoing Monitoring a Routine, Not a Fire Drill

Third-party risk doesn’t end when the contract is signed. In 2026, your program should show that monitoring is continuous and risk-based, not an occasional reaction to headlines or exam comments.

• Structured periodic reviews
  • Annual or semi-annual reviews for critical/high-risk vendors: updated SOC reports, security questionnaires, compliance attestations, key incident summaries.
  • Documented review notes, risk ratings, and follow-up items.
• Performance and risk monitoring
  • Track service disruptions, complaints tied to the vendor/partner, and any major incidents.
  • Review changes in ownership, leadership, geographic footprint, or business model that might affect risk.
• Escalation and issue management
  • Defined triggers for escalations to senior management or your Partner Bank.
  • A central issue log capturing vendor-related findings, remediation plans, and status.

Special Focus: Fintech–Bank Partnerships

For partner banks, regulators expect thorough oversight of fintech programs. For fintechs, partner banks expect you to be ready to open the kimono when they are examined. In 2026, both sides should aim for:

• “Exam-ready” documentation packages
  • For fintechs: a clean set of policies, risk assessments, monitoring schedules, training records, and independent reviews to provide to the partner bank.
  • For banks: program-level documentation that shows how you evaluate and monitor each fintech relationship.
• Clear division of responsibilities
  • Use “RACI-style” clarity: who is responsible, accountable, consulted, and informed for KYC, monitoring, SAR filing, complaints, marketing review, etc.
  • Document these responsibilities in program charters, SLAs, and oversight procedures.
• Regular governance touchpoints
  • Standing meetings between bank and fintech compliance/BSA teams.
  • Shared review of key metrics (alerts, SARs, complaints, exceptions, system performance) and upcoming product changes.

The goal is to move from transactional oversight (“Send us your policy doc”) to relationship governance with shared understanding and documentation.

2026 Action Steps for Goal #4

To bring this goal to life, consider adding these to your 2026 plan:

• Q1: Refresh your vendor/partner inventory and risk-tiering
  • Confirm you have a complete list and that risk ratings are current and documented.
• Q2: Standardize due diligence and ongoing review templates
  • Create right-sized questionnaires and review checklists for each risk tier.
• Q2–Q3: Review and update key contracts
  • Prioritize critical/high-risk vendors and fintech partners to ensure audit rights, SLAs, and compliance expectations are appropriately documented.
• Q3–Q4: Build an “exam-ready” third-party oversight file
  • For each critical vendor/partner, compile contracts, due diligence, monitoring evidence, issue logs, and governance minutes in one place.

By tightening third-party and fintech partner risk management in 2026, you’re protecting your organization from downstream failures and creating a compelling story for regulators and partner banks about how seriously you take your oversight responsibilities.

Goal #5: Build a Data-Driven Compliance Monitoring & Reporting Framework

Most institutions can show how busy their compliance teams are—policies updated, trainings completed, reviews performed. Fewer can clearly show how effective their program is at actually reducing risk. That’s where a data-driven monitoring and reporting framework becomes one of the most valuable goals you can set for 2026.

The aim isn’t to build a flashy dashboard for its own sake. It’s to give senior management, the Board, and partner banks clear, consistent visibility into where risk is increasing, where controls are working, and where attention is needed – without drowning them in noise.

Move From “Activity Reporting” to “Risk Insight”

A common pattern: compliance reports that list everything done (trainings, audits, reviews, policy changes) but say very little about what it means. In 2026, work toward reports that answer three simple questions:

1. Where are we seeing risk increase or decrease?
2. Where are we seeing issues repeat, escalate, or spread?
3. What are we doing about it – and is it working?

That means:

• Distinguishing between activity metrics (what you did) and risk metrics (what’s happening in the environment).
• Highlighting trends over time, not just snapshots.
• Framing the narrative in terms of impact and next steps, not just numbers.

Define the Right Mix of KPIs and KRIs

You don’t need 50 metrics. You need a balanced, manageable set that reflects your actual risk profile and program maturity.

Think in two buckets:

• KPIs (Key Performance Indicators) – how well your compliance processes are operating
  • % of planned monitoring and testing completed on time
  • % of staff with current required training
  • Average time to close issues or respond to high-risk complaints
  • % of high-risk customers with completed periodic reviews
• KRIs (Key Risk Indicators) – signals that risk may be increasing
  • Volume and severity of complaints by product or channel
  • Number and severity of audit/exam findings; repeat findings
  • SAR filing trends and typologies (for BSA/AML programs)
  • Sanctions alerts and true hits
  • Exception rates (policy overrides, pricing exceptions, underwriting exceptions)

Build Simple, Consistent Dashboards and Reports

You don’t need an enterprise GRC tool to get started. Even an Excel-based or slide-based dashboard can be effective if it’s clean, consistent, and repeated every quarter. Focus on:

• Standardized formats by audience
  • Management-level reports: more detail and operational metrics.
  • Board/committee reports: high-level KPIs/KRIs, trends, and key issues.
• Visuals that emphasize trends
  • Simple charts for complaints, findings, SARs, exceptions, and training completion over time.
  • Color-coding or risk ratings to highlight where attention is needed (e.g., red/yellow/green indicators).
• Narrative summaries
  • A concise “top 3–5 themes” section explaining what changed this period and why.
  • Clear notes on planned or in-progress remediation efforts.

Tie Metrics to Issue Management and Remediation

A data-driven framework only matters if it leads to decisions and actions. That’s where issue management comes in.

• Centralize issue tracking
  • Maintain a single log of findings, observations, and issues from audits, exams, monitoring, BSA reviews, and vendor oversight.
  • Capture root cause, owner, target remediation date, and status.
• Connect metrics to issue trends
  • Use KPIs/KRIs to spot repeat issues across business lines or products.
  • Elevate repeat or aging issues to senior management and the Board.
• Close the loop
  • Document verification that corrective actions were implemented and effective.
  • Update your risk assessments and monitoring plans based on what the data shows.

2026 Action Steps for Goal #5

To make this goal actionable, consider building these into your 2026 plan:

• Q1: Define your core metrics
  • Select a focused set of KPIs and KRIs for compliance, BSA/AML, consumer protection, and third-party risk.
  • Assign data owners and define how each metric will be calculated and reported
• Q2: Build a basic reporting template
  • Create management and Board/committee report templates with charts, tables, and a concise narrative section.
  • Pilot the new format for one or two reporting cycles, then refine based on feedback.
• Q2–Q3: Implement or enhance issue tracking
  • Stand up a central issue log (tool or spreadsheet) capturing all compliance-related issues and remediation plans.
  • Align your metrics to this log so you can show progress over time.
• Q3–Q4: Integrate metrics into governance
  • Make KPIs/KRIs and issue status a standing agenda item for Compliance Committee and Board meetings.
  • Periodically review whether your metrics still reflect your key risks, and adjust as your products, partners, and risk profile evolve.

By the end of 2026, a data-driven monitoring and reporting framework should give you something incredibly valuable: a clear, evidence-based story about your compliance program – where you’ve been, where you’re improving, and where you’re focusing next. That story is exactly what regulators, partner banks, and your own leadership want to hear.

Turning Goals Into an Actionable 2026 Roadmap

At this point, you’ve got the “what” – five big compliance goals that make sense on paper. The next challenge is the “how”: turning those goals into a realistic 2026 plan that your team can actually execute without burning out.

A strong roadmap doesn’t try to do everything at once. It sequences work based on risk, resources, and upcoming pressure points (exams, partner reviews, product launches). Think of this section as the bridge between your strategic goals and your day-to-day task list.

Prioritize and Sequence Based on Your Actual Risk

Not every organization needs to start in the same place. A community bank with a recent BSA exam may prioritize Goal #2 first; a fast-growing fintech under partner bank scrutiny might lead with Goals #1 and #4.

• Use your risk assessment as your compass
  • Look at your compliance and BSA/AML risk assessments, recent audit/exam reports, and partner feedback.
  • Flag areas rated “high” or “increasing” risk — those should anchor the first half of your 2026 roadmap.
• Map goals to quarters
  • Q1: Foundation work (CMS health check, updated BSA/AML risk assessment, vendor inventory refresh).
  • Q2: Build and formalize (monitoring plans, marketing review framework, metrics dashboards).
  • Q3: Deep dives and remediation (targeted reviews in BSA/AML, UDAAP, fair lending, third-party oversight).
  • Q4: Validation and readiness (follow-up testing, documenting progress, exam/partner prep).
• Be explicit about what is “now” vs. “later”
  • Each goal should have “2026 must-do” items and “defer to 2027 if needed” items.
  • Document these decisions so if a regulator asks, you can explain your reasoning.

Align Resources and Decide What to Build vs. Buy

Even the best roadmap fails if it assumes capacity you don’t actually have. 2026 planning should include a candid look at who will do the work and where you need help.  Ask yourself:

• What can we realistically handle in-house?
  • Routine monitoring, basic policy updates, and day-to-day issue management may sit with internal compliance staff.
  • Consider bandwidth: what will get dropped if you layer new projects on top of business as usual?
• Where does it make sense to bring in external support?
  • Independent BSA/AML reviews and model validations.
  • Internal audits of higher-risk areas (e.g., fair lending, UDAAP, third-party risk, sanctions).
  • Building or refreshing core frameworks (CMS, vendor risk, complaint management, metrics dashboards).
• Building or refreshing core frameworks (CMS, vendor risk, complaint management, metrics dashboards).
  • Clarify how Compliance, Risk, Audit, IT, InfoSec, and Operations intersect on key projects (e.g., BSA system changes, vendor risk enhancements).
  • Make sure responsibilities are clear so critical work doesn’t fall into the gaps.

A realistic 2026 roadmap is explicit about who owns each initiative, who supports it, and where external expertise will be leveraged to move faster and reduce rework.

Document the Plan and Socialize It With Stakeholders

A plan that lives only in the Compliance Officer’s head isn’t a plan—it’s a risk. To make your 2026 roadmap credible and durable, it needs to be documented, approved, and communicated. Consider:

• Create a concise 2026 Compliance Plan document
  • Summarize the five goals, key initiatives under each, and target timelines by quarter.
  • Tie initiatives back to risk assessments, exam/audit findings, partner feedback, and strategic objectives.
• Seek formal approval or acknowledgment
  • Present the plan to senior management and the Board or Compliance Committee.
  • Capture feedback, adjust where needed, and document approval in meeting minutes.
• Communicate with business units and partners
  • Share relevant portions of the plan with product owners, operations, BSA, marketing, and other key stakeholders.
  • Be clear about expectations, timelines, and how their teams will be involved.

Build in Checkpoints and Be Willing to Adjust

No plan survives 12 months without change. New products launch, guidance shifts, issues pop up. A good 2026 roadmap includes built-in checkpoints to reassess and adjust.

• Quarterly progress reviews
  • Use Compliance Committee or internal leadership meetings to review what’s been completed, what’s behind, and what’s changed.
  • Update timelines and priorities as new risks or opportunities emerge.
• Link checkpoints to your metrics
  • Use the KPIs/KRIs from Goal #5 to inform where you may need to shift focus mid-year.
  • If metrics signal increasing risk in a specific area, be prepared to pull that work forward.
• Document changes to the plan
  • When priorities shift, capture the rationale: new product, partner feedback, regulatory development, or emerging risk.
  • This documentation shows regulators that your program is dynamic and risk-based, not static.

How RADD Can Help

Planning and executing on these 2026 goals can feel overwhelming—especially if your team is already stretched thin with day-to-day compliance, BSA/AML, and exam prep. This is exactly where RADD comes in. We help institutions move from “we know what we should do” to “here’s what we’ve done, here’s what’s next, and here’s the documentation to prove it.”

RADD partners with community banks, credit unions, and fintechs to:

• Assess and strengthen your CMS foundation
• Design and document risk-based audit and monitoring plans
• Modernize BSA/AML & sanctions programs and conduct independent BSA/AML and sanctions audits or model validations
• Elevate consumer protection and third-party oversight
• Build data-driven reporting and Board visibility

Whether you need a fractional Compliance Officer, targeted project support (like a BSA/AML review or vendor risk refresh), or a full partner to help design and execute your 2026 roadmap, RADD’s team brings examiner-ready documentation, practical recommendations, and the capacity to get it all across the finish line.

Conclusion: Compliance Goals for 2026

As you look ahead to 2026, the question isn’t whether there’s enough work to do in compliance—it’s whether that work is focused on the right things, in the right order, and supported by the right structure.

By setting clear goals around CMS strength, BSA/AML and sanctions modernization, consumer protection and fair lending, third-party oversight, and data-driven monitoring and reporting, you give your institution a roadmap that is both defensible to regulators and genuinely valuable to your business. These aren’t abstract concepts; they’re practical levers you can pull to reduce risk, improve transparency, and make life easier when the next exam, audit, or partner review arrives.

The key is to resist the temptation to tackle everything at once. Start with your risk profile, sequence initiatives across the year, and be honest about where external support will help you move faster and avoid rework. A thoughtful 2026 plan doesn’t eliminate surprises – but it does ensure you’re not starting from zero when they show up.

If you’re ready to turn these goals into a concrete, examiner-ready 2026 roadmap, RADD can help.
Whether you need a one-time CMS or BSA/AML “health check,” a risk-based internal audit plan, support building out third-party oversight, or a fractional compliance partner to walk with you through the year, our team is here to help you plan – and execute – for success.

Invite your team to a planning conversation now rather than waiting for the next exam letter
Click here to schedule a discovery call with RADD – to review your current program, identify your highest-impact 2026 priorities, and start the year with a clear, documented plan.