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ARTICLE · 07 APRIL 2026

Modernizing AML/CFT: FinCEN Proposes Fundamental Reforms To Program Requirements

Jones Day
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On April 7, 2026, the Financial Crimes Enforcement Network ("FinCEN") issued a Notice of Proposed Rulemaking ("NPRM") to fundamentally reform anti-money laundering and countering the financing...

United StatesFinance and Banking
Jayant W. Tambe
Jayant W. Tambe
Nathan Brownback
Nathan Brownback
Michael Dawson
Michael Dawson
Abradat Kamalpour
Abradat Kamalpour
Nicholas Podsiadly
Nicholas Podsiadly
Mark W. Rasmussen
Mark W. Rasmussen
Alexander Wilson
Alexander Wilson
Brian R. Young
Brian R. Young
Michael Rust
Michael Rust
+1 more
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In Short

The Situation: On April 7, 2026, the Financial Crimes Enforcement Network ("FinCEN") issued a Notice of Proposed Rulemaking ("NPRM") to fundamentally reform anti-money laundering and countering the financing of terrorism ("AML/CFT") program requirements under the Bank Secrecy Act ("BSA"). The Federal Deposit Insurance Corporation ("FDIC"), National Credit Union Administration ("NCUA"), and Office of the Comptroller of the Currency ("OCC") issued a joint NPRM to implement and remain consistent with FinCEN's proposed changes.

The Change: The proposed rules would: (i) establish a two-tiered enforcement framework distinguishing program establishment from implementation; (ii) reorient compliance requirements toward a risk-based approach; (iii) expand FinCEN's oversight role; and (iv) recognize innovative technologies and law enforcement cooperation as mitigating factors when considering enforcement actions.

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