In case you missed it, FinCEN recently issued a Proposed Rule to “Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance”. This replaces the previously issued proposed rule; however, it does still incorporate many of the requirements of the 2020 AML/CFT Reform Act. The big takeaway is that this proposal is looking to place less focus on paperwork and box checking and more focus on mitigating higher-risk areas. It’s also addressed artificial intelligence and FinCEN’s plan to take a more active role in enforcement.
Emily gave a quick overview of this Proposed Rule in our April Monthly Connection. Here’s what she had to say.
Published 2026/04/29