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ARTICLE · 07 APRIL 2026

FinCEN Proposes Major Revisions To AML/CFT Program Requirements

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FinCEN has proposed a rule that would fundamentally reform anti-money laundering and countering the financing of terrorism program requirements for financial institutions under the Bank Secrecy Act. The proposal emphasizes risk-based resource allocation, requires documented risk-assessment processes, and expands FinCEN's role in bank supervision.

United StatesGovernment, Public Sector
A.J. Dhaliwal
A.J. Dhaliwal
Mehul Madia
Mehul Madia
Maxwell Earp-Thomas
Maxwell Earp-Thomas
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On April 7, FinCEN announced a proposed rule that would significantly revise anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements for financial institutions under the Bank Secrecy Act.

The proposal is framed as a broader effort to modernize AML/CFT compliance and supervision, reduce unnecessary compliance burden, and shift attention away from technical process issues and toward program effectiveness. FinCEN also states that the rule would supersede its July 2024 AML/CFT program proposal. Specifically, the proposal would:

  • Require “effective” AML/CFT programs. FinCEN would formally distinguish between establishing an AML/CFT program and maintaining it through implementation in all material respects, with that distinction carrying particular significance for bank supervision and enforcement.

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