In this episode of Corruption, Crime and Compliance, Michael Volkov examines FinCEN’s April 2026 proposal to rebuild the Bank Secrecy Act AML program rule around an effectiveness standard, with a two-prong test requiring that programs be both established (risk-based, built on four core elements, and kept current) and maintained (implemented in all material respects), along with a new enforcement threshold for banks limited to significant or systemic failures and explicit encouragement of AI and advanced analytics. At the same time, FinCEN is retreating from mandatory enhanced due diligence for domestic politically exposed persons, an effectiveness standard arriving amid deregulation and a rollback of beneficial ownership reporting, and AI monitoring tools that silently miss novel risks, make the appearance of compliance easier while making its substance harder to maintain. Volkov closes with practical steps: test programs against the two-prong standard, measure outcomes rather than activity, adopt a risk-based policy for domestic officials, govern and validate AI tools against the institution’s own risk profile, and avoid managing to the current enforcement climate.