Davis Polk AML/CFT head Dan Stipano was quoted in MoneyLaundering.com discussing obstacles to FinCEN implementing some of its proposed AML rule changes.

The article noted that a consequential section of the proposal would require the federal banking agencies to run any “significant” actions by FinCEN before taking them.

Dan said, “Without a very significant augmentation of their [FinCEN’s] resources, I don’t know how they’re going to be positioned to do this.”

“[The proposed rule changes] may lead [the banking agencies] to find other ways to get their point across without having to bring FinCEN into it,” he added.

“FinCEN’s Plan to Oversee Enforcement Raises Questions,” MoneyLaundering.com (April 9, 2026) (subscription required)

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