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ARTICLE · 29 MAY 2026

FinCEN’s Revisions To AML/CFT Program: Considerations For Financial Institutions

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On 7 April 2026, The Financial Crimes Enforcement Network (FinCEN) issued its notice of proposed rulemaking (NPRM or proposed rule) that would revise the requirements for anti-money laundering and countering the financing of terrorism (AML/CFT) compliance programs for financial institutions.

United StatesGovernment, Public Sector
Juan C. Zarate
Juan C. Zarate
Himamauli Das
Himamauli Das
Michele L. Malvesti
Michele L. Malvesti
Justina Rousseau
Justina Rousseau
Elizabeth Severinovskaya
Elizabeth Severinovskaya
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On 7 April 2026, The Financial Crimes Enforcement Network (FinCEN) issued its notice of proposed rulemaking1 (NPRM or proposed rule) that would revise the requirements for anti-money laundering and countering the financing of terrorism (AML/CFT) compliance programs for financial institutions.2 If adopted as is, the final program rules would become effective 12 months from their date of issuance. The comment period for the proposed rule ends on 9 June 2026.

In parallel, the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and National Credit Union Administration (NCUA) have issued a joint proposed rule that would revise the AML/CFT program requirements for their regulated institutions in order to align with the FinCEN proposed rule.3 The Federal Reserve Board of Governors is also expected to publish a similar proposed rule.

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