On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) that would formalize and, in certain respects, update the requirements for financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs under the Bank Secrecy Act (“BSA”).  While FinCEN has characterized the proposed rule as the centerpiece of Treasury’s broader effort to modernize the U.S. AML/CFT regulatory and supervisory framework, many of its core elements reflect longstanding statutory requirements and supervisory expectations.  The proposed rule fully supersedes a prior proposed rule FinCEN published on July 3, 2024, which the agency is withdrawing.  Concurrently, the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”), and the National Credit Union Administration (“NCUA”) (collectively, the “Agencies”) issued their own joint NPRM proposing substantially aligned amendments to their respective AML/CFT program rules for banks they supervise.  Public comments are due 60 days after publication in the Federal Register.

This alert summarizes the key provisions of both proposals, describes the proposed changes to bank supervision and enforcement, and identifies practical implications for financial institutions and compliance professionals.  As discussed below, many of the proposed requirements may be familiar to institutions with mature, risk-based AML/CFT programs.