The Office of the Comptroller of the Currency, FDIC, and NCUA published a joint notice of proposed rulemaking in April 2026 (with a comment period extending through June 9, 2026) that would fundamentally restructure AML/CFT program requirements for all national banks, federal savings associations, and credit unions. The proposed rule — developed concurrently with FinCEN’s parallel modernization initiative — would require institutions to formally integrate a risk assessment process into their AML/CFT programs, explicitly incorporate customer due diligence requirements, and establish a new notification and consultation framework before agencies initiate significant AML enforcement actions.
The requirement that FinCEN be consulted before an enforcement action is initiated represents a structural change in interagency AML governance, designed to ensure greater consistency across supervisory actions. For compliance officers and bank executives, the proposed rule is the most consequential regulatory development in the BSA/AML space in a generation. It signals that the ‘check-the-box’ era of AML compliance is ending: programs will be assessed on their effectiveness in identifying and mitigating specific, documented risks — not merely their administrative completeness. Institutions with underdeveloped risk assessment processes, weak board oversight, or transaction monitoring systems not calibrated to their actual customer risk profile will face the greatest implementation challenges.
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}