Daily Compliance Brief — FinCEN Proposes Rule to Strengthen AML Program Effectiveness

February 25, 2026

Signal

The U.S. Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule intended to refine and clarify expectations for anti-money laundering program effectiveness under the Bank Secrecy Act. The proposal emphasises risk-based alignment between AML controls and an institution’s specific risk profile, reinforcing outcome-oriented compliance over procedural formality.

The rulemaking reflects continued implementation of the Anti-Money Laundering Act reforms, with a focus on ensuring that AML programs are reasonably designed to detect, prevent, and report illicit finance in line with articulated national priorities.

Why it matters

Compliance teams may need to reassess how AML program effectiveness is documented, tested, and evidenced, particularly in relation to enterprise-wide risk assessments and resource allocation.

Institutions should evaluate governance structures, monitoring calibration, and independent testing frameworks to ensure demonstrable alignment between identified risks and control design, anticipating more explicit supervisory focus on measurable outcomes rather than checklist adherence.