FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

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On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness; this announcement was followed on July 19, 2024, with parallel proposed rulemakings by the Office of the Comptroller of the Currency, the Federal Reserve System, the Federal Deposit Insurance Corporation and the National Credit Union Administration.

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