FinCEN’s April 2026 proposed rule marks a major shift in AML/CFT compliance by redefining how programs are evaluated, enforced, and managed under the Bank Secrecy Act. In this episode, Michael Volkov breaks down the proposal’s most significant changes, including the new two-pronged framework distinguishing program design from implementation, a higher threshold for enforcement focused on systemic failures, and expanded expectations for risk-based compliance and governance. The rule also encourages the use of innovative technologies like artificial intelligence while requiring stronger board oversight and U.S.-based compliance leadership. With a 12-month implementation timeline and a clear push toward outcome-driven compliance, this proposal signals a fundamental transformation in how financial institutions should approach AML risk management.