On April 10, 2026, FinCEN published the Proposed Rule to implement provisions of the AML Act and amend FinCEN regulations prescribing the minimum requirements for AML/CFT programs for a broad range of financial institutions including banks, casinos and card clubs, money services businesses (MSBs), brokers or dealers in securities (broker-dealers), mutual funds, insurance companies, futures commission merchants (FCMs) and introducing brokers in commodities (IBCs).

The Proposed Rule reflects Treasury’s priority of BSA reform and modernization and is consistent with Treasury Secretary Scott Bessent’s April 2025 remarks, where he indicated that Treasury would “advocate for changes to the AML/CFT framework to truly focus on national security priorities and higher-risk areas.” The Proposed Rule would introduce several reforms to AML/CFT program compliance and supervision.

Click here to read the full GT Alert.

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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

Photo of Shirin Afsous Shirin Afsous

Shirin Afsous is an experienced litigator in the field of commercial litigation. As a proactive professional, she is adept at client interaction and excels at crafting strategic case plans. Her areas of experience span across a vast array of sectors including financial services…

Shirin Afsous is an experienced litigator in the field of commercial litigation. As a proactive professional, she is adept at client interaction and excels at crafting strategic case plans. Her areas of experience span across a vast array of sectors including financial services litigation, labor & employment, government contracts, and commercial disputes. Her proficiency extends beyond the borders of her home state, as she skillfully handles cases across the nation in both state and federal courts. Moreover, she is a frequent participant in administrative proceedings, often providing invaluable assistance to clients embroiled in governmental investigations. As a first chair attorney, Shirin has taken the lead in numerous matters, showcasing her leadership and litigation skills. Her deep experience encompasses a wide range of legal proceedings, from drafting and research to preparing witnesses for trial. She is skilled at conducting depositions and arguing dispositive motions, proving her versatility in different aspects of litigation.

Photo of Erika Cabo Erika Cabo

Erika Cabo focuses her practice on regulation, structuring, and compliance of, and transactions in, blockchain and digital assets, derivatives and complex structured products. She represents a diverse range of clients, including global blockchain technology companies, cryptocurrency exchanges, token sellers, cryptocurrency funds, broker-dealers, major

Erika Cabo focuses her practice on regulation, structuring, and compliance of, and transactions in, blockchain and digital assets, derivatives and complex structured products. She represents a diverse range of clients, including global blockchain technology companies, cryptocurrency exchanges, token sellers, cryptocurrency funds, broker-dealers, major global investment banks and financial institutions. Erika advises on tokenization of real-world assets, blockchain-based capital markets transactions, blockchain token sales, and trading and investment in digital assets.

Erika engages with regulators and policymakers on behalf of clients, including representing blockchain platforms before the SEC’s Crypto Task Force and drafting comment letters on proposed SEC rules. She has represented technology companies in advanced policy initiatives such as the CLARITY Act and market structure bills, advocating for clear regulatory definitions and safe harbor frameworks to support responsible innovation in the digital asset space.

Erika counsels financial institutions, blockchain platforms, centralized and decentralized digital asset exchanges and technology companies on securities and commodities issues, custody rule requirements, broker-dealer matters and cross-border regulatory issues. She structures deals and negotiates U.S. and cross-border agreements involving digital assets and complex financial products and regularly helps clients navigate evolving federal and state securities and commodities laws and regulations.

In her derivatives practice, Erika advises on all aspects of derivatives and structured products transactions across the U.S. and Latin America, including regulatory strategy, compliance, negotiation, structuring and documentation. Erika advises both regulated entities and end users on Dodd-Frank Act and Commodity Exchange Act regulation and compliance, and on the structuring of innovative hedging, trading, and risk management solutions.

In a previous role, Erika practiced in the New York office of a global law firm, where she represented buy-side and sell-side financial institutions, corporates and technology companies in the U.S. and Latin America in derivatives trading, documentation, and regulatory matters. She also counseled technology companies on securities laws in the firm’s blockchain and digital assets practice. She is fluent in Spanish.

Photo of Janiell "Alexa" Gonzalez Janiell "Alexa" Gonzalez

Janiell A. Gonzalez focuses her practice on helping bank and non-bank financial institutions navigate the federal and state regulatory environment governing payments, lending, and consumer financial services. She represents and advises industry leaders in the development and implementation of emerging payment products, including…

Janiell A. Gonzalez focuses her practice on helping bank and non-bank financial institutions navigate the federal and state regulatory environment governing payments, lending, and consumer financial services. She represents and advises industry leaders in the development and implementation of emerging payment products, including Internet- and mobile-based payment products and services. Janiell regularly assists clients with federal money services business registrations, nationwide state money transmitter and lending licensing applications, and ongoing licensing compliance issues. Janiell helps clients design Bank Secrecy Act (BSA)/Anti-Money Laundering (AML)/Office of Foreign Asset Control (OFAC) compliance policies and procedures, conducting independent risk assessments, and providing company-wide training on these topics.

Janiell also serves as the Deputy General Counsel for the Hispanic National Bar Association’s charitable arm, HNBA VIA, where she provides advice on a broad range of legal issues affecting the organization.