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?

Pick your institution type for an instant read on whether you're in scope — then see exactly which sections of your own policies this changes.

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

FinCEN

FinCEN GTO: Southwest Border MSBs Must Report Cash Transactions $1K–$10K

FinCEN has issued a Geographic Targeting Order (GTO) requiring certain money services businesses operating along the U.S. southwest border to report and retain records of cash transactions between $1,000 and $10,000 — well below the standard $10,000 CTR threshold — and to verify the identity of customers presenting such transactions. This is a significant AML/BSA escalation for covered MSBs in the targeted geography, effectively lowering the transaction monitoring and KYC trigger point for cash dealings. Non-compliance with a GTO carries the same penalties as violations of the Bank Secrecy Act.

OCC

Regulators Clarify What Banks Can (and Can't) Tell Customers About SARs

Five federal regulators — OCC, Federal Reserve, FDIC, FinCEN, and NCUA — jointly clarified the rules around SAR confidentiality when institutions communicate with customers about potentially fraudulent transactions. The statement addresses a persistent compliance tension: institutions must protect SAR confidentiality (including not 'tipping off' subjects) while still being able to warn or question customers about suspicious activity without inadvertently disclosing a SAR has been filed. Compliance officers should review customer-facing fraud communication workflows to ensure staff are not crossing the tipping-off line.

FinCEN

FinCEN Proposes Cutting Off UAE Branches of Banque Misr Over Money Laundering Risk

FinCEN is proposing to designate the UAE-based branches of Banque Misr as a primary money laundering concern under Section 311 of the USA PATRIOT Act. If finalized, U.S. financial institutions would be prohibited from opening or maintaining correspondent accounts for Banque Misr UAE, required to take reasonable steps to block transactions involving Banque Misr UAE flowing through foreign correspondent accounts, and required to apply enhanced due diligence to foreign correspondent accounts to prevent their use for such transactions. Any firm that maintains foreign correspondent banking relationships — including crypto exchanges and fintechs with banking partners — must ensure Banque Misr UAE exposure is identified and addressed.

FinCEN

FinCEN Finalizes Narrowed Beneficial Ownership Reporting Rules Under CTA

FinCEN has finalized rules that significantly narrow who must report beneficial ownership information (BOI) under the Corporate Transparency Act: U.S. person beneficial owners and U.S. person company applicants are now exempt from reporting requirements, and U.S. persons are no longer required to update information previously submitted to obtain a FinCEN ID. Crypto exchanges, MSBs, neobanks, and other regulated entities that are themselves 'reporting companies' or that rely on CTA data for KYC/customer due diligence purposes need to reassess their compliance obligations and any downstream processes built around BOI collection.

Stay ahead of every rule change

PliOS monitors FinCEN, OCC, OFAC, the SEC and CFTC and tells you which of your policies each new rule affects — with the edit already drafted. Start free.

Run My Free Assessment