Statement on Proposal to Implement the BSA Program Rule
Summary
FDIC Chairman Travis Hill delivered a statement at the April 7, 2026 Board meeting describing a proposal to implement the BSA Program Rule under the 2021 Anti-Money Laundering Act. The proposal would establish a risk-based supervisory approach, allowing banks to allocate resources toward high-risk activities and away from low-risk compliance exercises. Banks could rely on Treasury's National Priorities for risk assessments, while regulators would retain authority to act against serious violations such as drug cartel cash deposits or terrorist financing.
What changed
The statement announces the FDIC Board's consideration of a proposal implementing the BSA Program Rule under the AML Act of 2020. The proposal would shift BSA supervision from a compliance-focused, check-the-box approach to a risk-based model that focuses on areas most important to law enforcement and national security. Banks would be required to establish and implement BSA programs based on their individual risk profiles rather than universal requirements.
Affected parties, particularly community banks that receive limited law enforcement feedback, should monitor this proposal closely. If adopted, the rule could reduce compliance burden for lower-risk banking activities while maintaining regulatory tools for serious violations. Banks currently devoting significant resources to low-value BSA compliance may have opportunities to reallocate resources, and the proposal's explicit direction away from penalties for procedural 'foot faults' could reduce enforcement risk for well-intentioned institutions.
What to do next
- Monitor for the formal publication of the BSA Program Rule proposal and any associated comment period
- Review current BSA/AML compliance programs for alignment with proposed risk-based approach
- Assess whether community bank risk assessment methodologies incorporate Treasury's National Priorities
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.
Statement by Chairman Travis Hill on the Proposal to Implement the BSA Program Rule
Chairman Travis Hill Statement, Board Meeting April 7, 2026 In 2021, Congress passed the AML Act, 1 the most substantial overhaul of the Bank Secrecy Act (BSA) in a generation, and the first since the USA Patriot Act was signed into law in 2001. In the AML Act, Congress directed FinCEN and the banking agencies to, among other things, modernize the BSA, ensure that bank BSA programs focus on high-risk areas that are important to law enforcement and national security agencies, and encourage technological innovation to more effectively counter money laundering and the financing of terrorism.
Banks currently devote enormous resources to complying with BSA requirements, while it is unclear to what extent much of that effort actually helps further law enforcement or national security efforts. Meanwhile, the risk of large fines due to BSA violations incentivizes banks to “debank” customers by denying or closing accounts.
Today, the FDIC Board is considering perhaps the most important of the reforms Congress envisioned in the AML Act. The proposal embraces a risk-based approach to supervision and would affirmatively encourage banks to allocate resources away from lower risk activities and toward higher risk activities. It would require that programs be established and effectively implemented in light of each bank’s particular risk assessment and profile. Banks, notably community banks that receive little direct feedback from law enforcement, would be able to rely on the Treasury Department’s “National Priorities” as they develop their risk assessments. The proposal seeks to avoid penalizing banks for “foot faults” or approaching exams as “box checking” exercises, and instead focuses on better aligning regulation with risk and avoiding having to wait until a massive failure to take action. At the same time, the proposal would still maintain the tools necessary for regulators to take action if, for example, a bank is accepting duffel bags full of cash from drug cartels or funding terrorists overseas.
I want to thank FDIC staff for their work on this proposal, along with the staffs of our interagency partners, and I look forward to receiving comments.
| 1 | Anti-Money Laundering Act of 2020, Pub. L. No.116-283, §§ 6001-6511, 134 Stat. 4547-4633 (2021). |
Last Updated: April 7, 2026
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