FinCEN proposes risk-based AML/CFT program reform

What changed

FinCEN proposed superseding its 2024 AML-program proposal with a framework emphasizing effective, reasonably designed, risk-based programs; distinguishing design from implementation deficiencies; clarifying testing and audit roles; and formalizing consultation on major supervisory actions.

Who it affects

• Banks, broker-dealers, MSBs, mutual funds, futures firms, insurers, and other BSA-covered institutions

What is still open

• Final program standards, regulator-specific implementation, and transition timing

What it means for an advisor

• Compare current risk assessment, governance, testing, resource allocation, issue classification, and regulator-engagement processes with the proposal while retaining operative rules.