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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.

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OCC

OCC Hits American Express with $350M Penalty for BSA/AML Failures

The OCC issued a cease-and-desist order and a $350 million civil money penalty against American Express National Bank for deficiencies in its BSA/AML compliance program. This is a high-profile enforcement action signaling that regulators are actively scrutinizing AML program adequacy at large financial institutions. Compliance officers should treat this as a benchmark for the level of rigor expected in BSA/AML controls.

OCC

OCC Comptroller Highlights Community Bank Efforts to Fight Financial Fraud

Comptroller Gould convened community bankers in Minnesota to discuss strategies for combating financial fraud, signaling continued OCC focus on fraud as a supervisory priority. While directed at community banks, the discussion reflects broader regulatory attention to fraud controls that fintech partners and bank-affiliated crypto firms should also take note of.

FinCEN

FinCEN Withdraws Proposed Rule Targeting CVC Mixing as AML Risk

FinCEN is withdrawing its Section 311 finding and proposed rulemaking that would have classified international convertible virtual currency (CVC) mixing as a class of transactions of primary money laundering concern, along with associated enhanced recordkeeping and reporting requirements. This means the specific regulatory burden proposed for CVC mixing transactions will not move forward. Compliance teams should note that while the formal rule is withdrawn, mixing activity may still carry AML risk warranting internal controls.

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