Fed proposes risk-based BSA/AML program requirements for supervised banks - JD Supra
The Federal Reserve proposes risk-based BSA/AML program requirements for supervised banks, potentially impacting money services businesses that rely on bank partnerships.
Aforeworn detected this change in the Money Services & Money Transmitters space on July 21, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Medium urgency. Money services businesses (MSBs), payment processors, crypto firms, remittance providers, fintech wallets that maintain bank accounts or partner with Fed-supervised banks. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Proposal stage; comment period likely open. Monitor for final rule and effective date.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Money Services & Money Transmitters continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
Fed proposes that supervised banks implement risk-based BSA/AML programs, which may tighten compliance expectations for bank-MSB relationships.
Who it affects
Money services businesses (MSBs), payment processors, crypto firms, remittance providers, fintech wallets that maintain bank accounts or partner with Fed-supervised banks.
What you must do
Review and update your BSA/AML program to align with risk-based principles; ensure your bank partners are aware and compliant.
Deadline
Proposal stage; comment period likely open. Monitor for final rule and effective date.
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