A Congressional Research Service update from March 19, 2026 confirms that FinCEN has yet to finalize several critical rulemakings required under the Anti-Money Laundering Act of 2020 (AMLA), despite statutory deadlines having passed.
Among the delayed items is a final rule on the national AML/CFT priorities framework, which banks and financial institutions must incorporate into their risk-based compliance programs. FinCEN also remains behind on regulations covering antiquities dealers, a sector identified as a high-risk conduit for money laundering by transnational criminal organizations. The delays compound existing compliance uncertainty: financial institutions must align programs with national priorities that are not yet codified, leaving risk-based program development in a holding pattern.
From a compliance risk perspective, the absence of finalized guidance increases the likelihood of supervisory inconsistency — examiners from different agencies may apply varying interpretations of what constitutes an ‘effective’ AML program. There is also a whistleblower dimension: FinCEN launched a dedicated webpage in February 2026 to confidentially accept tips on money laundering and sanctions violations, signalling that tip-driven enforcement may fill enforcement gaps where formal rulemaking has lagged. Compliance officers should treat the rulemaking delay not as a reprieve but as a period of elevated supervisory risk, during which robust documentation of reasonable, good-faith program design choices will be essential.
By FCCT Editorial Team
, an independent military force, and allied militias in Sudan raped several dozen women and girls in West Darfur’s capital, El Geneina, and those fleeing to Chad between late April and late June 2023, Human Rights Watch said today. The assailants appear to have targeted people because of their Massalit ethnicity and, in some cases, because they were known activists.){kind=link}