Designed for busy in-house counsel and compliance professionals, this newsletter summarizes key domestic and international anti-money laundering (AML) regulatory and enforcement developments from the past few months, with links to primary sources.
The first half of 2026 has been marked by two parallel AML/BSA trends: regulators are emphasizing risk-based modernization and burden reduction, while enforcement agencies continue to focus on willful misconduct. The most notable AML developments during the second quarter of 2026 were regulatory announcements, not enforcement actions. It was a particularly busy three months for the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN):
FinCEN’s AML/CTF Program Overhaul: On April 7, 2026, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) designed to reform anti-money laundering (AML) and countering the financing of terrorism (CFT) programs under the Bank Secrecy Act (BSA).
Overall, FinCEN appears to be seeking a more modern, flexible, and effectiveness-oriented AML/CFT regime that places greater emphasis on institutions to assess their own risks, allocate compliance resources proportionately, and demonstrate that their programs produce useful outcomes for law enforcement and national security.
In practical terms, near-term homework for financial institutions includes starting with a gap assessment now on risk-assessment methodology, examining how resources are allocated by risk. Financial institutions should also start to assess their governance approvals, officer location/authority, and how to actually evidence “effectiveness.”
The proposed rule expressly supersedes FinCEN’s prior proposed rule, issued on July 3, 2024, which has now been withdrawn. The public comment period closed June 9, 2026, and the agency proposed a 12-month implementation period after issuance of the final rule.
Simultaneously, the Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and National Credit Union Administration released companion proposed rules to align their BSA program requirements with FinCEN’s new framework. Notably, the Board of Governors of the Federal Reserve System has not joined the other regulators; however, it is unclear why.
You can find more information about the NPRM in our Client Alert.
FinCEN’s Proposed BSA Whistleblower Framework: Another significant April development was FinCEN’s proposed rule to implement the BSA whistleblower program. On April 1, 2026, FinCEN issued an NPRM to establish a formal whistleblower program under the BSA. Historically, many major AML enforcement matters originated from regulator exams or law enforcement investigations. A mature whistleblower regime could significantly expand the pipeline of AML cases.
Treasury Proposes New Rules for Payment Stablecoin Issuers Under the Genius Act: On April 8, 2026, FinCEN and the Office of Foreign Assets Control (OFAC) jointly published proposed rules under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act), treating permitted payment stablecoin issuers (PPSIs) as financial institutions under the BSA for the first time. The proposal signals Treasury’s intent to integrate PPSIs into the United States’ core AML/CFT compliance framework through a combination of familiar BSA and OFAC requirements and new, stablecoin-specific controls. The centerpiece of the FinCEN portion of the NPRM is the proposal at 31 C.F.R. § 1033.210 to require PPSIs to establish and maintain an “effective” AML/CFT program. The OFAC portion of the NPRM is also significant. Although PPSIs are, by definition, already U.S. persons that are required to comply with U.S. sanctions laws and regulations, the GENIUS Act goes further by expressly requiring PPSIs to maintain an effective sanctions compliance program. This requirement would be the first time federal law has explicitly mandated that a particular category of U.S. person maintain such a program. For more information, please see our Client Alert.
FinCEN Expands Section 314(b) Information-Sharing Guidance to Incorporate Fraud: On June 12, 2026, FinCEN issued updated guidance in significantly broadens the scope of voluntary information sharing among financial institutions under Section 314(b) of the USA PATRIOT Act to include suspected fraud offenses. FinCEN explicitly clarified that fraud offenses are specified unlawful activities (SUAs) for money laundering offenses and therefore subject to the information-sharing safe harbor. You can find more information in our Client Alert.
FinCEN Activity Centered on Iran and FIFA: On May 11, 2026, FinCEN took two actions seemingly in response to current events. First, FinCEN issued an alert in an attempt to stop money laundering activity involving Iran’s Islamic Revolutionary Guard Corps. Second, FinCEN issued a notice flagging the threat of human trafficking during the 2026 FIFA World Cup. The notice urges financial institutions located in or around 2026 FIFA World Cup host cities to increase vigilance for potential human trafficking activity.
On the enforcement front, the focus continues to shift from purely regulatory violations to willful misconduct. Notable enforcement actions include the following:
Arrest of Maduro Regime Ally and Former Minister Alex Saab on Money Laundering Charges Involving Venezuelan Food Contracts and Oil: Venezuela’s former Minister of Industry and National Production, Alex Saab, was arrested pursuant to an indictment unsealed on May 18, 2026, in the Southern District of Florida charging him for his alleged role in a sprawling international money laundering conspiracy involving the corruption and exploitation of a Venezuelan public welfare program intended to provide food to vulnerable Venezuelans.
Justice Department Announced Resolution with EagleBank: On June 30, 2026, EagleBank, a state member community bank with operations in Maryland, Virginia, and the District of Columbia, and its parent entity, Eagle Bancorp Inc., entered into a non-prosecution agreement and agreed to pay over $9.7 million to resolve the Justice Department’s investigation into violations of the Bank Secrecy Act. Consistent with a focus on willful misconduct, according to the statement of facts in support of the agreement, for a decade, EagleBank knowingly allowed certain clients to operate a check-kiting scheme.