On April 7, 2026, FinCEN proposed the most consequential rewrite of the AML/CFT program rule in a decade. Join us for a practitioner-first breakdown of what changed, why it matters, and what your program should do before the June 9 comment deadline.
About this webinar
FinCEN isn't asking you to update forms. They're asking you to rethink what good looks like.
The new proposed rule replaces technical, check-the-box compliance with a single question: Does your program actually work? It introduces a two-prong framework that separates how a program is designed from how it's executed, and tells examiners, in writing, to stop confusing the two. It also gives explicit supervisory credit to banks that use AI to demonstrate program effectiveness.
Neda Shapourian, Unit21's General Counsel, breaks down the legal and regulatory implications of the NPRM alongside Christina Rea-Baxter and Sarah Beth Felix. Together, they'll walk through what actually changed, what it means for your next exam, and what steps to take before the June 9 comment deadline.
What you'll see in action
- The two-prong framework explained: How FinCEN separates program design from implementation, and why examiners can no longer conflate the two
- AI gets supervisory credit: What FinCEN's explicit AI language actually says, what it doesn't say, and why it's a credit, not a mandate
- What your risk assessment needs now: How to refresh documentation and tie effectiveness evidence back to FinCEN's AML/CFT Priorities
- The legal fine print: What General Counsel and compliance teams should be reading between the lines, including the 30-day FinCEN consultation gate and independent testing clarifications
- How leading institutions are already building the case: What operational AI looks like when it's designed to demonstrate program effectiveness to regulators
