Treasury and Federal Banking Agencies Propose Sweeping Changes to the AML/CFT Compliance Framework

The first week of April 2026 produced a series of proposed federal rules that, if finalized, would meaningfully reshape the U.S. anti-money laundering and countering the financing of terrorism (“AML/CFT”) framework:

• On April 7, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced a notice of proposed rulemaking (“FinCEN’s Proposal”) that would fundamentally reshape the framework governing financial institutions’ AML/CFT programs under the Bank Secrecy Act (“BSA”).
• In parallel, the Office of the Comptroller of the Currency (the “OCC”), the Federal Deposit Insurance Corporation (the “FDIC”), and the National Credit Union Administration (the “NCUA” and, collectively, the “Banking Agencies”) issued a joint proposed rulemaking (the “Banking Agencies’ Proposal”) that would align the Banking Agencies’ AML/CFT supervisory frameworks and enforcement practices with the new standards proposed by FinCEN.
• On April 8, FinCEN and Treasury’s Office of Foreign Assets Control issued a joint proposed rulemaking (the “Stablecoin Proposal” and, together with the FinCEN and Banking Agencies’ Proposals, the “Proposals”) to establish a comprehensive AML/CFT compliance framework for permitted payment stablecoin issuers consistent with the requirements of the Guiding and Establishing National Innovation for U.S. Stablecoins Act.

These Proposals continue a steady stream of rulemaking activity from FinCEN and the Banking Agencies in recent weeks.¹  Taken together, these rulemakings reflect a coordinated effort across the federal government to modernize and recalibrate AML/CFT and sanctions compliance requirements and expectations, extend the BSA regime to payment stablecoin activities, and enhance FinCEN’s interpretive authority over BSA-related regulations.   Should the new Proposals be adopted following the conclusion of the 60-day comment period in June 2026, financial institutions, financial service providers, and particularly stablecoin issuers will be required to evaluate and, where necessary, adapt their existing AML/CFT programs to ensure alignment with evolving regulatory expectations during the subsequent 12-month implementation phase.

The Proposals do not, however, represent a unanimous consensus.  The Board of Governors of the Federal Reserve System (the “FRB”) did not join the OCC, FDIC, and NCUA in issuing the Banking Agencies’ Proposal, leaving an open question as to whether the FRB will align its own AML/CFT supervisory framework with the proposed changes.

In the attached Client Alert, we discuss and summarize key takeaways from these three Proposals as well as what they may mean for the U.S. illicit finance legal and regulatory framework.

1. The Stablecoin Proposal is among the latest in a series of rulemakings implementing the GENIUS Act; we discuss the OCC’s recent payment stablecoins proposal in a previous post and the FDIC’s corresponding proposal in another prior post.