Davis Polk AML/CFT head Dan Stipano was featured on AML RightSource’s podcast AML Conversations to discuss FinCEN’s newly proposed AML/CFT rule reforms. In the episode, Dan speaks about the genesis of the proposal and its key structural changes, including the bifurcation of program establishment and implementation, the formal incorporation of national AML priorities, and the clarification of the U.S.-based compliance officer requirement.

“The Program Rule is really a centerpiece of the BSA and the administration’s BSA reform efforts, so it’s a very important rulemaking,” Dan said.

Discussing the proposed provision that provides FinCEN the new role as a gatekeeper over federal banking agency supervisory and enforcement actions, he noted, “This is a game changer.”

“Up until now, the federal banking agencies have acted pretty independently, pretty autonomously in terms of taking supervisory actions and enforcement actions that are based on BSA requirements,” Dan explained. “But if this rule is finalized, they won’t be able to do that anymore. The way I read it, if they want to take not just an enforcement action but a significant AML/CFT supervisory action…they have to vet with FinCEN and give FinCEN 30 days to respond. And presumably, FinCEN will have to review the action.”

“AML Conversations: Unpacking the AML/CFT Program Rule: Key Changes and Industry Implications,” AML RightSource’s AML Conversations (April 9, 2026)

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