All in Regulatory Update

On April 7, 2026, the FDIC, the OCC, and the NCUA jointly issued a proposed rule to amend the respective requirements for their supervised institutions to establish and maintain effective risk-based anti-money laundering and countering the financing of terrorism (AML/CFT) programs designed to identify, assess, and mitigate risks of illicit finance. The amendments are intended to align each agency’s AML/CFT rules with changes concurrently proposed by FinCEN.

On April 7, 2026, the OCC and the FDIC jointly issued a final rule that codifies the elimination of reputation risk from their supervisory programs. The agencies believe that banking regulators’ use of the concept of reputation risk as a basis for supervisory criticisms increases subjectivity in banking supervision without adding material value from a safety and soundness perspective.