AML/CFT Program Requirements - Joint Notice of Proposed Rulemaking

Detected April 7th, 2026

Summary

The FDIC, OCC, and NCUA have issued a joint notice of proposed rulemaking to amend AML/CFT program requirements for supervised banks and credit unions. The proposed amendments would align agency regulations with FinCEN requirements and the Anti-Money Laundering Act of 2020, introducing risk-based program requirements, US-based designated AML/CFT officer requirements, and a new FinCEN consultation framework for supervisory and enforcement actions.

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What changed

The proposed rule would amend existing BSA/AML requirements to incorporate AML Act of 2020 provisions, including mandatory risk-based approaches directing resources toward higher-risk customers. It would explicitly incorporate FinCEN's customer due diligence requirements, require US-based designated AML/CFT officers, and establish that only significant or systemic program failures would trigger enforcement actions. A new FinCEN consultation framework for certain agency actions is also proposed.

Affected banks and credit unions should evaluate whether their current AML/CFT programs meet the proposed risk-based standards and ensure compliance officer requirements are satisfied. The 60-day comment period provides an opportunity to influence rulemaking before finalization.

What to do next

Review current AML/CFT program against proposed risk-based requirements
Verify designated AML/CFT officer is located in the US and accessible to regulators
Submit comments during 60-day comment period

Source document (simplified)

Agencies Request Comment on Anti-Money Laundering/Countering the Financing of Terrorism Proposed Rule

April 2026 Agencies Request Comment on Anti-Money Laundering/Countering the Financing of Terrorism Proposed Rule ALEXANDRIA, VA (April 7, 2026) – The Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration (NCUA) (collectively, the “Agencies”) today invite public comment on a proposed rule to amend the respective requirements for their supervised institutions to establish and maintain effective risk-based anti-money laundering and countering the financing of terrorism (AML/CFT) programs designed to identify, assess, and mitigate risks of illicit finance. The amendments are intended to align each agency’s AML/CFT rules with changes concurrently proposed by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

The Bank Secrecy Act (BSA) refers to the statutory framework imposing various AML/CFT regulatory requirements on financial institutions, including banks and credit unions supervised by the Agencies. In 2020, Congress passed the Anti-Money Laundering Act of 2020 (AML Act), which directed FinCEN and the Agencies to modernize and strengthen the AML/CFT regulatory framework to encourage more effective outcomes for financial institutions, regulators, law enforcement, and national security agencies. The Agencies are proposing to revise their respective regulations to reflect these broader revisions to the BSA, as well as to ensure consistency between FinCEN’s and the Agencies’ separately authorized compliance program requirements.

Among other changes, the proposed rule would:

Incorporate the AML Act provision that a bank’s AML/CFT program should be risk-based, including ensuring that banks direct more attention and resources toward higher-risk customers and activities, consistent with the risk profile of the institution, rather than toward lower-risk customers and activities.
Describe the requirements for a bank to establish an AML/CFT program; explicitly incorporate FinCEN’s existing customer due diligence requirement; and clarify that a bank’s designated AML/CFT officer must be located in the U.S. and accessible to regulators.
Require that once a bank has properly established its AML/CFT program, the institution maintains that program in all material respects. In addition, the proposed rule would clarify that only significant or systemic failures to implement a properly established program would warrant an “AML/CFT enforcement action” or a “significant AML/CFT supervisory action.”
Enhance FinCEN’s role in the Agencies’ supervision and enforcement process by establishing a new consultation framework for certain actions by the Agencies.
Clarify that banks may share any information with FinCEN related to certain AML/CFT supervisory and enforcement actions. Comments on the proposed rule are due 60 days after the date of publication in the Federal Register.

Attachment(s):

Notice of Proposed Rulemaking: Anti-Money Laundering and Countering the Financing of Terrorism Program Requirements

Media Contacts

| Agency | Contact | Phone |
| --- | --- | --- |
| FDIC | Brian Sullivan | 202.412.1436 |
| OCC | Andrea Cox | 202.649.6870 |
| NCUA | Ashley Gordon | 703.346.9550 |

The NCUA was created by the U.S. Congress to regulate, charter and supervise federal credit unions. With the backing of the full faith and credit of the United States, the NCUA operates and manages the Share Insurance Fund, insuring the deposits of more than 145 million account holders in all federal credit unions and most state-chartered credit unions.

Last modified on

04/07/26