FinCEN proposes overhaul of financial institution AML/CFT programs

FinCEN has proposed a new rule to fundamentally reform anti-money laundering and countering the financing of terrorism programs for financial institutions.

The agency said the proposal would replace and withdraw its July 3, 2024 AML/CFT program proposal. FinCEN said the new rule is meant to modernize how financial institutions design their compliance programs under the Bank Secrecy Act.

The proposal comes alongside parallel action by the FDIC, OCC and NCUA, which are seeking comment on aligned AML/CFT program requirements for banks and credit unions. The FDIC said its board approved a related notice of proposed rulemaking the same day.

According to the agencies, the changes are intended to support more risk-based compliance programs and to better align supervisory expectations across the banking system. ACAMS described the proposal as moving supervision away from a check-the-box model and toward effectiveness.

FinCEN issued the proposal on April 7, 2026, opening a new comment process that could lead to broader changes in how AML programs are structured and examined.

For banks and other covered firms, the immediate next step is to review the proposal before the comment deadline and assess how it would affect internal controls, governance and reporting workflows.