The Financial Crimes Enforcement Network (FinCEN) is overhauling its Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) framework under the Anti-Money Laundering Act of 2020. The centerpiece is a June 2024 Notice of Proposed Rulemaking (NPRM) that replaces rigid, checkbox compliance with a more flexible, risk-based model.
Under the proposed rules, financial institutions must conduct formal risk assessments tailored to their specific business activities, customer base, and geography. They will also be required to align their programs with FinCEN's published national AML/CFT priorities, which are updated at minimum every four years to reflect evolving threats.
The modernization push also emphasizes governance and innovation. Boards of directors will be required to formally approve and oversee AML/CFT programs, and institutions are encouraged to adopt AI and machine learning tools to reduce false positives and improve suspicious activity detection.
FinCEN continues to facilitate public-private collaboration through its FinCEN Exchange and TechSprints programs. Key implementation milestones include the NPRM comment period closing in September 2024, a new real estate transaction transparency rule effective March 1, 2026, and a delayed rollout of the investment adviser AML rule, now set for January 1, 2028.