FinCEN Proposes Rule to Modernize AML/CFT Program Requirements

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking on April 7, 2026, to modernize and reform anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements under the Bank Secrecy Act (BSA). FinCEN described the proposal, issued pursuant to the Anti-Money Laundering Act of 2020 (AMLA), as a shift from a process-driven approach to one prioritizing measurable effectiveness, risk-based resource... By: Orrick, Herrington & Sutcliffe LLP