OCCBSA / AMLApril 10, 2026

OCC, FDIC & NCUA Propose Risk-Based AML/CFT Program Rules for Banks

The OCC, FDIC, and NCUA are jointly proposing amendments to require banks and credit unions to maintain AML/CFT programs that are risk-based, outcomes-focused, and aligned with the concurrent FinCEN AML Act rulemaking — modernizing a framework that has remained largely unchanged for decades. Banks with crypto-related customers or services should pay particular attention, as the risk-based approach may reshape how they assess and document illicit finance risks associated with digital assets. This proposal runs in parallel with the FinCEN proposal and compliance officers should review both together.

What to do

Map your current AML/CFT program against the proposed risk-based requirements, identify documentation and governance gaps, and coordinate with your BSA Officer to draft a comment letter or engage your banking regulator during the comment period.

Who this affects

Bank / Credit UnionTrust CompanyFintech / Neobank

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

OCC

OCC Comptroller Speaks on Debanking Report Findings

Comptroller Gould publicly discussed findings from the OCC's supervisory review of debanking practices at the largest national banks, signaling heightened regulatory attention to how banks terminate or restrict customer accounts. For crypto firms, fintechs, and MSBs that have experienced account closures, this signals potential policy and supervisory pressure on banks to justify debanking decisions. Compliance officers at banks should expect greater scrutiny of their account-closure policies and documentation.

OCC

OCC Publishes Report on Debanking Practices at the Nine Largest National Banks

The OCC released a formal report detailing its supervisory findings on how the nine largest national banks it oversees — including JPMorgan Chase, Bank of America, Citibank, and others — have conducted debanking activities, a practice that has disproportionately affected crypto firms, MSBs, and fintechs. This report is a significant regulatory signal that the OCC is scrutinizing blanket or poorly justified account terminations and may indicate forthcoming supervisory guidance or expectations. Crypto and fintech compliance officers should review the findings to understand the regulatory landscape around banking access and use it to engage their banking partners.

OCC

OCC Hits Bank of America with Record $750M BSA/AML Penalty

The OCC levied a historic $750 million civil money penalty against Bank of America for violations of the Bank Secrecy Act and its implementing regulations, the largest such penalty in OCC history. This action signals that regulators are prepared to impose landmark fines for systemic BSA/AML compliance failures, sending a clear message to all regulated institutions — including banks that partner with or provide services to crypto and fintech firms — that AML program deficiencies will be met with severe consequences.

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.

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