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FinCENBSA / AMLApril 10, 2026

FinCEN Proposes Sweeping Overhaul of AML/CFT Program Requirements

FinCEN is proposing to fundamentally reform BSA AML/CFT program requirements for all covered financial institutions, aiming to make programs more risk-based and outcomes-focused while enhancing FinCEN's own supervisory and enforcement role alongside federal banking regulators. This rulemaking, which implements the AML Act of 2020, would affect virtually every regulated entity — including crypto firms and fintechs — and could significantly change how AML programs are structured, documented, and examined. Compliance officers should review the proposal carefully and consider submitting comments to shape the final rule.

What to do

  • Read the proposed rule, assess gaps between your current AML/CFT program and the proposed requirements, and prepare a comment letter or engage trade associations before the comment deadline.

Who this affects

Crypto ExchangeCrypto CustodianWallet ProviderMoney Services BusinessPayments CompanyFintech / NeobankBank / Credit UnionTrust CompanyBroker-Dealer / RIA

Does this affect your program?

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Source

Read the official publication

This radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.

Related developments

OCC

OCC Flags Updated FinCEN Guidance on Voluntary Info-Sharing Between Institutions

The OCC is drawing attention to FinCEN's refreshed Section 314(b) Fact Sheet, which clarifies how financial institutions can voluntarily share information about suspected money laundering or terrorist financing with one another under a statutory safe harbor from liability. Compliance officers should review the updated guidance to ensure their institution's 314(b) program reflects the latest expectations, particularly around fraud-related information sharing, which was a key focus of the update.

Federal Reserve

Fed Proposes Updated AML/CFT Program Rules for Banks Under AML Act of 2020

The Federal Reserve is proposing to update AML/CFT program requirements for the banks it supervises, aligning with FinCEN's own proposed rulemaking and parallel proposals from the OCC, FDIC, and NCUA — all stemming from the Anti-Money Laundering Act of 2020. The rule would require supervised banks to maintain risk-based programs designed to identify, assess, and mitigate illicit finance risks and generate more useful information for law enforcement. Banks with crypto or fintech partnerships should pay close attention, as updated AML/CFT program standards will likely flow through to vendor and correspondent relationships.

FinCEN

FinCEN Proposes Expanding Huione Group Designation to Cover H-Pay Service PLC

FinCEN is proposing to expand the existing Section 311 designation of Huione Group — already identified as a primary money laundering concern — to explicitly include H-Pay Service PLC and introduce a 'successor entity' definition, preventing the group from evading restrictions by rebranding. The existing special measure prohibiting U.S. financial institutions from maintaining correspondent or payable-through accounts for Huione Group remains in force. Any firm that processes crypto or fiat payments must screen for H-Pay Service PLC and future successor entities named under this action.

OCC

OCC Proposes BSA/AML and Sanctions Rules for Payment Stablecoin Issuers

The OCC, in coordination with FinCEN and OFAC, has proposed regulations implementing BSA/AML and sanctions compliance requirements specifically for permitted payment stablecoin issuers under its jurisdiction, as required by the GENIUS Act. This is a landmark proposal that will establish formal AML program, KYC, and sanctions screening obligations for federally supervised stablecoin issuers. Compliance officers at stablecoin issuers and banks exploring stablecoin activities should treat this as a top-priority rulemaking.

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