AML/CFT Program Requirements Proposed Rule
Summary
FDIC, OCC, and NCUA jointly published a proposed rule on April 7, 2026 to amend AML/CFT program requirements for supervised banks and credit unions. The amendments would align agency rules with FinCEN's concurrent proposals and the Anti-Money Laundering Act of 2020, including risk-based program requirements, U.S.-based compliance officer mandates, and enhanced FinCEN consultation procedures. Comments are due 60 days after Federal Register publication.
What changed
The proposed rule would amend AML/CFT program requirements for FDIC-supervised banks, OCC-supervised national banks and federal thrifts, and NCUA-supervised credit unions. Key changes include requiring risk-based AML/CFT programs that direct resources toward higher-risk customers, mandating that designated compliance officers be located in the U.S. and accessible to regulators, clarifying that only significant or systemic program failures warrant enforcement action, and establishing a new FinCEN consultation framework for certain supervisory actions.
Banks and credit unions should evaluate whether current AML/CFT programs align with the proposed risk-based approach and assess whether existing compliance officer arrangements meet the U.S. location requirement. Institutions should prepare to comment on provisions that may create operational burdens or ambiguity, particularly around the thresholds for significant versus minor program deficiencies and the scope of information sharing with FinCEN.
What to do next
- Review proposed AML/CFT amendments and assess impact on current compliance program
- Identify any required changes to risk-based procedures or compliance officer arrangements
- Submit comments before the 60-day deadline
Archived snapshot
Apr 8, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Agencies Request Comment on Anti-Money Laundering/Countering the Financing of Terrorism Proposed Rule
Joint Release
Federal Deposit Insurance Corporation
National Credit Union Administration
Office of the Comptroller of the Currency
April 7, 2026 WASHINGTON – 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)
Contact(s)
FDIC: Brian Sullivan, (202)-412-1436 OCC: Andrea Cox, (202) 649-6870 NCUA: Ashley Gordon, (703) 346-9550
Last Updated: April 7, 2026
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