FinCEN AML Program Modernization Proposal

June 2026

FinCEN’s proposed AML/CFT modernization rule marks a shift from checkbox compliance to measurable effectiveness. Regulators are increasingly focused on whether AML controls actually work—not just whether processes are followed.
Our white paper explores key changes, including enhanced risk assessments, risk-based resource allocation, SAR effectiveness, governance, operationalization of AML/CFT priorities, and the growing role of analytics, automation, and AI.

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June 16, 2026

FinCEN AML Program Modernization Proposal

June 16, 2026

FinCEN’s proposed AML/CFT modernization rule marks a shift from checkbox compliance to measurable effectiveness. Regulators are increasingly focused on whether AML controls actually work—not just whether processes are followed.

Our white paper explores key changes, including enhanced risk assessments, risk-based resource allocation, SAR effectiveness, governance, operationalization of AML/CFT priorities, and the growing role of analytics, automation, and AI.

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May 26, 2026

April 14, 2026

Harmonizing Derivatives Error Reporting

April 14, 2026

Recent updates from the CFTC and CSA are reshaping how firms approach derivatives reporting errors. With the introduction of materiality thresholds, relief on historical corrections, and clearer guidance on what constitutes a “significant” error, regulators are signaling a shift toward pragmatic, risk-based reporting. We break down these changes and what they mean in practice, including: New 5% (CFTC) and 10% (CSA) error thresholds, Relief on “dead swaps” and limitations on historical remediation, and Key operational differences firms must manage across jurisdictions.

FinCEN AML Program Modernization Proposal

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