On April 7, 2026, FinCEN issued a proposed rule to reform AML and CFT program requirements under the Bank Secrecy Act. The proposal would modernize and harmonize requirements for casinos and money services businesses while retaining certain MSB-specific provisions, and it superseded FinCEN's prior July 3, 2024 proposal.
What changed
FinCEN proposed a new AML/CFT program framework for covered institutions, including MSBs. The proposal also included treatment of permitted payment stablecoin issuers, including adding PPSIs to the list of entities excluded from the definition of money services business in the proposed text while separately imposing AML/CFT, SAR, CTR, and recordkeeping requirements on PPSIs.
Compliance perspective
MSBs should assess how the proposed framework would affect risk assessments, program design, governance, and documentation, especially if they are active in digital payments or stablecoin-related activities. Firms should also identify whether any business line could fall within the proposed PPSI framework.
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