Robert Maddox Quoted in Bank Director on the Second Trump Administration's Increased Enforcement Focus

Bradley partner Robert Maddox was quoted in Bank Director emphasizing that banks should use the changing regulatory environment as an opportunity to reevaluate and strengthen their BSA/AML programs.

“This is an opportunity to sit down and reassess your BSA/AML program overall,” Maddox said.

Maddox stressed that leadership must be able to demonstrate the quality of the program. “Every bank will have an established program. The question for senior management and the board is, ‘Is it good enough, and can we prove that it is?’”

Maddox also highlighted the importance of carefully documenting compliance decisions, especially when banks make risk-based judgments such as account closures or suspicious activity report, or SAR, determinations.

Maddox emphasized that defensibility matters as much as perfection. “What you do and how you memorialize the decisions you make are absolutely critical.”

He added that banks can withstand scrutiny even if regulators later disagree with a decision, provided the reasoning is properly documented: “We can use core values, risk tolerance, risk structure, and we can make those decisions, but as long as we document those decisions, we can be wrong and that’s fine. We can defend it.”

The full article, “What the Fed Crackdown on Drug Trafficking Means for Your Bank,” was published by Bank Director on May 22, 2026.