Worldwide AML Regulation Map

On 13 October 2026, FinCEN assessed a $1.2 billion civil money penalty against Bank of America, N.A., for willful Bank Secrecy Act violations involving deficiencies in its AML program, correspondent-bank due diligence and suspicious activity reporting. The release also reports separate, concurrent OCC ($750 million) and OFAC ($11.6 million) actions; those amounts are not part of the FinCEN penalty.

FinCEN formally withdrew the December 2020 NPRM that would have imposed transaction reporting, records and customer identity verification requirements for specified digital-asset transfers involving unhosted or otherwise covered wallets. The withdrawal took effect on 6 October 2026; the proposal never became a final binding requirement.

FinCEN withdrew its October 2023 section 311 finding concerning international convertible virtual currency mixing, together with the proposed special measure requiring enhanced recordkeeping and reporting. The withdrawal was published and took effect on 6 October 2026; the special measure was never finalized.

FinCEN published a proposed rule on 5 October 2026 identifying a class of transactions involving A7 Network-controlled non-US companies as a primary money-laundering concern related to Russian illicit finance and proposing a prohibition on specified fund transmittals by covered US financial institutions. Public comments are due by 4 November 2026. This is a proposal, not a final enforceable prohibition.

OFAC amended the Cuban Assets Control Regulations effective 30 September 2026. Among the financial-sector changes, the amendments extend the Cuba Restricted List prohibition to indirect financial transactions, remove the U-turn general license for transactions originating and terminating outside the United States, and remove the general authorization for U.S. banking institutions to maintain certain accounts for Cuban independent private sector entrepreneurs.

FinCEN, jointly with federal banking agency staff, issued two new FAQs and updated one existing FAQ addressing state-issued mobile driver’s licenses and other government-issued verifiable digital credentials that may be used to verify natural-person customers under the Customer Identification Program Rule. The guidance clarifies how digital credentials fit within existing CIP identity-verification requirements rather than creating a new standalone identification regime.

On 28 August 2026, FinCEN announced a notice of proposed rulemaking under Section 311 of the USA PATRIOT Act identifying Banque Misr UAE as a foreign financial institution of primary money laundering concern and proposing to bar U.S. financial institutions from maintaining correspondent accounts for it, together with additional due-diligence measures. The proposal applies to the UAE operation, not all Banque Misr branches. This is a proposed restriction, not evidence of a final rule or operative prohibition.

FinCEN issued a final rule making permanent the BOI reporting exemptions introduced in the March 2025 interim rule.

On 19 March 2026, the U.S. District Court for the Eastern District of Texas vacated FinCEN’s Residential Real Estate Rule. FinCEN and the Department of Justice appealed, but while the order remains in force reporting persons are not required to file Real Estate Reports and are not liable for failing to do so.

FinCEN granted exceptive relief from identifying and verifying beneficial owners every time an existing legal-entity customer opens another account.

FinCEN’s final delay rule prevented the investment-adviser AML/CFT rule from commencing on 1 January 2026 and moved the scheduled compliance/effective date to 1 January 2028.

FinCEN postponed the Residential Real Estate Rule reporting start from 1 December 2025 to 1 March 2026.

Public Law 119-27 created a comprehensive regulatory framework for permitted payment stablecoin issuers and provides for treatment of those issuers as financial institutions for BSA and sanctions purposes, subject to statutory effectiveness and implementing rules.

FinCEN narrowed the Corporate Transparency Act reporting-company definition to certain foreign entities registered to do business in the United States and exempted domestic entities and U.S. persons from BOI reporting.

CFATF states that the United States officially became a member on 4 December 2024 during its 59th Plenary.

FinCEN finalized BSA AML/CFT program, SAR and related requirements for covered registered investment advisers and exempt reporting advisers. The rule was enacted as a future-effective change and was subsequently delayed before its original commencement date.

FinCEN issued a nationwide reporting rule for certain non-financed transfers of residential real property to legal entities and trusts.

FinCEN published the original BOI reporting final rule implementing the Corporate Transparency Act; the rule later took effect in 2024 before the reporting perimeter was narrowed in 2025 and made permanent in 2026.

The FY2021 National Defense Authorization Act enacted the Anti-Money Laundering Act of 2020 and the Corporate Transparency Act, modernising the BSA framework and creating a federal beneficial-ownership reporting architecture.

FinCEN’s CDD Rule established explicit beneficial-owner identification and verification requirements for covered legal-entity customers.

FinCEN clarified how BSA regulations apply to users, administrators and exchangers of convertible virtual currency, establishing the federal MSB analysis used for many virtual-asset business models.

Residential mortgage lenders and originators became subject to AML program and SAR requirements.

FinCEN implemented BSA requirements for prepaid access providers and sellers.

FinCEN implemented enhanced due-diligence requirements for certain foreign correspondent banking relationships.

U.S. AML requirements expanded for private banking and correspondent accounts and additional covered sectors including jewelers and insurance.

Public Law 108-458 amended the BSA to create authority for reporting certain cross-border electronic transmittals of funds where Treasury determines reporting is necessary to combat money laundering and terrorist financing, subject to statutory feasibility safeguards.

U.S. regulators implemented customer identification program requirements and additional SAR obligations for covered sectors.

Implementation extended AML programs and SAR obligations across additional financial sectors and strengthened information-sharing controls.

The USA PATRIOT Act expanded AML/CFT requirements, information sharing and registration obligations after the 2001 terrorist attacks.

Money services businesses became subject to suspicious activity reporting requirements.

The U.S. established a national money-laundering strategy and the HIFCA framework.

United States is one of the 13 founding members of the Asia/Pacific Group on Money Laundering established in Bangkok on 27 February 1997.

FinCEN and the federal banking supervisors replaced fragmented criminal-referral reporting with a single Suspicious Activity Report process for banks and other depository institutions. The unified SAR became effective on 1 April 1996 and created a centralised reporting stream for law enforcement and regulatory use.

Historical FinCEN/GAO membership evidence identifies United States among the 14 first Egmont Group members; Egmont's official history dates the founding meeting to 9 June 1995.

U.S. law added money services business registration and related BSA reporting measures.

U.S. law introduced suspicious activity reporting as a core BSA/AML tool.

FATF records United States as a member since 1990.

The U.S. Department of the Treasury established FinCEN in 1990; FinCEN subsequently became the designated administrator of the Bank Secrecy Act and the U.S. financial intelligence unit.

The 1988 Act broadened the financial-institution perimeter and required purchaser identity verification for monetary instruments above $3,000.

The Money Laundering Control Act made money laundering a federal crime, prohibited structuring to evade CTR filings, expanded forfeiture and strengthened BSA compliance procedures.

In California Bankers Association v. Shultz, the U.S. Supreme Court rejected constitutional challenges to core BSA reporting and recordkeeping requirements. The decision preserved the legal foundation on which the federal transaction-reporting regime could develop.

Congress established the Bank Secrecy Act framework for financial recordkeeping and reporting, including reporting of large cash transactions and identity/record requirements.