# FinCEN proposes risk-based AML/CFT program reform

> 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.

- URL: https://riadefi.com/regulation/2026-04-07-fincen-aml-program-modernization-proposal/
- Posture: Proposal · not in effect
- Authorities: Financial Crimes Enforcement Network
- Event date: 2026-04-07
- Version: 1, published 2026-08-07 (first published 2026-08-07)
- Advisor-relevant: yes

This entry records a proposal. It does not change the law unless it is adopted.

## 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.

## Sources

1. [FinCEN proposes risk-based AML/CFT program reform](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) · Financial Crimes Enforcement Network · 2026-04-07


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Published by Ketju Research on RIADeFi (https://riadefi.com). Educational research for financial professionals; not investment, legal, tax, or compliance advice.