Risk-Based AML/CFT Reform: What Financial Institutions Need to Know About the Joint Banking Agency and FinCEN Proposals

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The latest episode of the Consumer Finance Monitor podcast examines a significant and coordinated regulatory initiative that could reshape anti-money laundering and countering the financing of terrorism (AML/CFT) compliance across the financial services industry.

In this episode, host Alan Kaplinsky and guest Celia Cohen, a partner in Ballard Spahr’s White Collar Defense and Investigations Group, analyze the joint notice of proposed rulemaking issued by the federal banking agencies Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and National Credit Union Administration—alongside a parallel proposal from Financial Crimes Enforcement Network (FinCEN).

Together, these proposals represent one of the most important efforts in years to modernize AML/CFT compliance frameworks, moving the system toward a more risk-based, effectiveness-driven model.

Key Topics Discussed Include:

• A Shift Away from “Check-the-Box” Compliance
• “Establish and Maintain” — and Prove It Works
• SAR Filings and the Challenge of Judgment Calls
• Impact Across Financial Institutions
• Regulatory Signals: A Coherent Direction
• What Institutions Should Be Doing Now

The Consumer Finance Monitor podcast will continue tracking developments as the rulemaking process advances and will revisit the topic when final rules are issued.

Consumer Finance Monitor is hosted by Alan Kaplinsky, Senior Counsel at Ballard Spahr, and the founder and former chair of the firm's Consumer Financial Services Group. We encourage listeners to subscribe to the podcast on their preferred platform for weekly insights into developments in the consumer finance industry.

View a transcript of the recording here.

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