FinCEN's AML overhaul proposed

FinCEN published a proposal to rewrite how banks design anti‑money‑laundering programmes, shifting expectations toward an explicitly risk‑based, intelligence‑led framework. The draft would require firms to show their AML/CFT programmes are “effective, risk‑based and reasonably designed” and better align programme design with enterprise risk assessments and SAR decisions (wilmerhale.com). Legal advisers say the change increases emphasis on documented rationale linking typologies, alerts and staffing to stated risks (jdsupra.com).