On April 7, 2026, FinCEN announced a proposed rule that would shift AML/CFT supervision away from process compliance and toward program effectiveness. The rule would ask financial institutions to show that their AML programs combat threats as they change and are capable of producing useful outcomes for law enforcement and national security agencies.
For compliance and audit teams, the direction is clear. It will no longer be enough to maintain static rules, large manual queues, and periodic policy reviews. AML programs will need to demonstrate that detection coverage matches the institution's real threat environment, that controls are updated when products or behavioral patterns change, and that investigative resources are focused on higher-risk activity.
FinCEN does not mandate any specific technology. However, the proposal expressly supports AI-first monitoring tools when they improve AML/CFT effectiveness. Conway helps financial institutions move from manual, brittle AML workflows to adaptive detection and investigation systems. To learn more, contact team@conway.ai.