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Anti-Money Laundering and Countering the Financing of Terrorism Programs NPRM

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Summary

FinCEN has released a Notice of Proposed Rulemaking (NPRM) regarding Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Programs. The proposed rulemaking seeks public comment on potential new or revised requirements for financial institutions' AML/CFT programs. This represents a significant regulatory initiative that may affect compliance obligations across the financial services sector.

What changed

FinCEN has issued an NPRM on Anti-Money Laundering and Countering the Financing of Terrorism Programs. The proposed rulemaking would establish or modify requirements that financial institutions must follow to develop, implement, and maintain effective AML/CFT programs. This could include updates to program structure, risk assessment expectations, or enhanced due diligence requirements.

Financial institutions subject to FinCEN jurisdiction should carefully analyze how these proposed requirements would impact their existing compliance frameworks. Institutions should evaluate whether their current AML/CFT policies, procedures, and controls would need to be updated, and prepare substantive comments addressing any concerns or suggestions for the proposed framework during the open comment period.

What to do next

  1. Review the proposed AML/CFT program requirements in detail
  2. Prepare and submit public comments before the deadline
  3. Assess impact on current compliance programs and internal controls

Archived snapshot

Apr 7, 2026

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Last updated

Classification

Agency
FinCEN
Instrument
Consultation
Legal weight
Non-binding
Stage
Consultation
Change scope
Substantive

Who this affects

Applies to
Banks Broker-dealers Financial advisers
Industry sector
5221 Commercial Banking 5231 Securities & Investments 5222 Fintech & Digital Payments
Activity scope
AML program compliance CFT program development Suspicious activity reporting
Geographic scope
United States US

Taxonomy

Primary area
Anti-Money Laundering
Operational domain
Compliance
Compliance frameworks
BSA/AML OFAC Sanctions
Topics
Sanctions Securities Financial Services

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