The proposal would require banks to show anti-money laundering programs are effective, while a later FinCEN rewrite in April 2026 exposed a split with the Federal Reserve.
The Federal Reserve and three other major banking regulators have invited public comment on proposed changes to the rules governing bank anti-money laundering and counter-terrorism financing programs. The amendments would shift the framework from a process-based approach to an outcomes-focused standard, meaning banks would need to show their AML and CFT controls actually work rather than simply maintain compliant policies on paper. The proposal, directed by the AML Act of 2020, would also require formal risk assessments that incorporate FinCEN’s national priorities, including corruption, fraud, transnational criminal organizations, and terrorism financing. Comments were due 60 days after publication in the Federal Register. The broader rulemaking later diverged when FinCEN (U.S. financial crimes watchdog) issued an April 2026 Notice of Proposed Rulemaking that effectively replaced the original mid-2024 joint proposal, with the OCC, FDIC, and NCUA aligning to FinCEN’s updated approach while the Federal Reserve did not issue a parallel proposal. The changes do not directly address specific crypto tokens or digital assets, though they sit alongside separate efforts such as the forthcoming GENIUS Act, which would apply AML/CFT and sanctions requirements to permitted payment stablecoin issuers.