On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “FinCEN NPRM”) to reform anti-money laundering and countering the financing of terrorism (“AML/CFT”) program requirements under the Bank Secrecy Act (“BSA”) for all regulated financial institutions. In a parallel Notice of Proposed Rulemaking (the “Banking Agency NPRM”), two of the three federal banking regulators — the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) — proposed conforming amendments to the AML/CFT program rules for the banking entities they supervise, as did the National Credit Union Administration (“NCUA”). The Board of Governors of the Federal Reserve System (“FRB”) did not join the Banking Agency NPRM.
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