Bank AML/CFT Program Requirements (AML Act of 2020 Implementation)

Current understanding

The Federal Reserve, in coordination with FinCEN, OCC, FDIC, and NCUA, is proposing to require its supervised banking organizations to establish risk-based Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) programs that conform to the Anti-Money Laundering Act of 2020. The proposal aligns program requirements across federal banking regulators and updates expectations for risk assessments, internal controls, independent testing, designated compliance personnel, training, and customer due diligence. Status: proposed rule.

Evidence log

• 2026-10-06 — Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal: cross-connection with fincen-crypto-mixing-section-311: Withdrawal of the class-wide mixing special measure means banks and money transmitters interacting with CVC mixers rely on general BSA/AML program obligations rather than tailored Section 311 recordkeeping and reporting. (novelty: 3)
• 2026-10-06 — Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets; Withdrawal: cross-connection with crypto-digital-assets: Withdrawal of the unhosted-wallet AML proposal removes a planned crypto-specific extension of the broader bank BSA/AML program obligations. (novelty: 3)
• 2025-09-03 — Stop Chinese Fentanyl Act of 2025: cross-connection with stop-chinese-fentanyl-act: Mandatory designation of Chinese opioid traffickers would expand OFAC-listed counterparties that banks must screen under AML/CFT program obligations. (novelty: 2)

Open questions

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