Regulatory and Strategic Affairs Division Financial Crimes Enforcement Network P.O. Box 39 Vienna, VA 22183 Docket No. FINCEN-2026-0034 RIN 1506-AB72
Chief Counsel’s Office Attention: Comment Processing Office of the Comptroller of the Currency 400 7th Street SW Suite 3E-218 Washington, DC 20219 Docket No. OCC–2024–0005 RIN 1557-AF14
Jennifer M. Jones, Deputy Executive Secretary Attention: Comments/Legal OES Federal Deposit Insurance Corporation 550 17th Street NW Washington, DC 20429 RIN 3064-AF34
Melane Conyers Ausbrooks, Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, VA 22314-3428 Docket No. NCUA-2024-0033 RIN 3133-AG08
Re: Anti-Money Laundering and Countering the Financing of Terrorism Programs
Dear Sir or Madam:
The Conference of State Bank Supervisors (“CSBS”)1 provides the following comments on the parallel proposals from the Financial Crimes Enforcement Network (“FinCEN”)2 and the Office of the Comptroller of the Currency (“OCC”), Federal Deposit Insurance Corporation (“FDIC”), and the National Credit Union Administration (“NCUA”) (collectively, the “agencies”)3 to reform anti-money laundering and countering the financing of terrorism (“AML/CFT”) program requirements (“program rule”).
The proposal aims to modernize Bank Secrecy Act (“BSA”) requirements, promote a principles- and risk-based AML/CFT regime, and bring greater supervisory consistency, and focus on material AML/CFT program risks. CSBS supports these objectives and offers the following considerations and recommendations:
Formally distinguishing between and separately evaluating AML/CFT program design and program implementation would benefit financial institutions and supervisors.
A risk-based AML/CFT regime should support both the prioritization of higher risk activities and deemphasis of lower risk activities.
An optional FinCEN consultation process for AML/CFT enforcement actions and significant supervisory actions balances consistency with examination efficiency and effectiveness.
Regulatory and Strategic Affairs Division
Financial Crimes Enforcement Network
P.O. Box 39
Vienna, VA 22183
Docket No. FINCEN-2026-0034
RIN 1506-AB72
Chief Counsel’s Office
Attention: Comment Processing
Office of the Comptroller of the Currency
400 7th Street SW
Suite 3E-218
Washington, DC 20219
Docket No. OCC–2024–0005
RIN 1557-AF14
Jennifer M. Jones, Deputy Executive Secretary
Attention: Comments/Legal OES
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429
RIN 3064-AF34
Melane Conyers Ausbrooks, Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314-3428
Docket No. NCUA-2024-0033
RIN 3133-AG08
Re: Anti-Money Laundering and Countering the Financing of Terrorism Programs
Dear Sir or Madam:
The Conference of State Bank Supervisors (“CSBS”)1 provides the following comments on the parallel proposals from the Financial Crimes Enforcement Network (“FinCEN”)2 and the Office of the Comptroller of the Currency (“OCC”), Federal Deposit Insurance Corporation (“FDIC”), and the National Credit Union Administration (“NCUA”) (collectively, the “agencies”)3 to reform anti-money laundering and countering the financing of terrorism (“AML/CFT”) program requirements (“program rule”).
The proposal aims to modernize Bank Secrecy Act (“BSA”) requirements, promote a principles- and risk-based AML/CFT regime, and bring greater supervisory consistency, and focus on material AML/CFT program risks. CSBS supports these objectives and offers the following considerations and recommendations:
Read the full comment letter.
CSBS is the nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and the U.S. territories.
FinCEN, Proposed Rule, Anti-Money Laundering and Countering the Financing of Terrorism Programs, 91 Fed. Reg. 18704 (Apr. 10, 2026).
OCC, FDIC, and NCUA, Notice of Proposed Rulemaking, Anti-Money Laundering and Countering the Financing of Terrorism Programs, 91 Fed. Reg. 18304 (Apr. 10, 2026).