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ARTICLE · 04 JUNE 2026

FinCEN Proposes Fundamental Reform Of AML/CFT Program Requirements

McDermott Will & Schulte
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On April 7, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a notice of proposed rulemaking (the FinCEN Proposed Rule)...

United StatesFinance and Banking
Melissa G.R. Goldstein
Melissa G.R. Goldstein
Donald J. Mosher
Donald J. Mosher
Leel Sinai
Leel Sinai
Betty Santangelo
Betty Santangelo
Kyle B. Hendrix
Kyle B. Hendrix
Luke De Mott
Luke De Mott
Daniel J. Jacobi
Daniel J. Jacobi
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On April 7, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a notice of proposed rulemaking (the FinCEN Proposed Rule) that would fundamentally reform the anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements applicable to financial institutions under the Bank Secrecy Act (BSA) as amended by the USA PATRIOT Act and the Anti-Money Laundering Act of 2020 (AML Act). The FinCEN Proposed Rule, which implements key provisions of the AML Act of 2020. The FinCEN Proposed Rule includes proposed rules revising the AML/CFT program requirements for each type of financial institution with a BSA program obligation, including banks, casinos, money services businesses (MSBs), broker-dealers, mutual funds, insurance companies, and futures commission merchants (FCMs), introducing brokers in commodities (IBCs); dealers in precious metals, precious stones, or jewels; operators of credit card systems; loan or

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