Federal Reserve Follows (To a Degree) FinCEN and Other Banking Agencies in Proposing Sweeping AML/CFT Program Reforms
Wilmer Hale
"On July 7, 2026, the Board of Governors of the Federal Reserve System issued its own Notice of Proposed Rulemaking that would substantially revise the anti-money laundering and countering the financing of terrorism (AML/CFT) requirements applicable to Board-supervised banks under the Bank Secrecy Act. Although the Board’s announcement stated that the NPRM is intended to align with proposed changes made in the April rulemaking, in now issuing its own NPRM, the Board is taking a path by not including a provision of the April rulemaking that would see FinCEN as the gatekeeper of AML/CFT enforcement actions."
