FinCEN Issues Proposed Rule Revising The AML Program Requirements For Financial Institutions

I. Summary

On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a long-awaited new Notice of Proposed Rulemaking (NPRM or Proposed Rule) substantially revising the anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements applicable to financial institutions under the Bank Secrecy Act (BSA).¹ The Proposed Rule kicks off the most significant overhaul of financial institutions’ AML/CFT program obligations in years and implements key provisions of the Anti‑Money Laundering Act of 2020 (AML Act), including Congress’s directive that AML programs must be both “reasonably designed to assure and monitor compliance” and “risk-based.”² Later the same day, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA) issued their own joint Notice of Proposed Rulemaking to align their BSA compliance programs with