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CyberEyeQ

Actionable Regulatory Intelligence

Financial Regulation • Friday, April 25, 2026

Today's Top Story

FinCEN AML/CFT Program Reform: From Paperwork to Effectiveness

On April 7, FinCEN proposed sweeping reforms to AML/CFT compliance under the Bank Secrecy Act. The centerpiece: a shift from transaction-reporting volume to effectiveness-based compliance.

Key changes: Enforcement now focuses only on significant or systemic failures. New innovation safe harbor permits AI/ML tools without prior approval. Mandatory FinCEN consultation before major enforcement actions. Simplified reporting for smaller institutions.

Why it matters: This is the most fundamental BSA overhaul in decades. Your AML program can now prioritize outcomes over checkbox compliance.

Due date: June 9, 2026 (45 days)

DEADLINE ALERT: Basel III Endgame Re-Proposal — Comments Due June 18, 2026 (54 days)

The re-proposal cuts GSIB capital requirement increases in half: a 4.8% net increase vs. original 16-19%. The agencies removed the dual stack approach.


Also Today

SEC Reg S-P Smaller Entity Deadline — June 3, 2026

Advisers with less than $1.5B AUM must comply with updated privacy and cybersecurity rules: 30-day breach notification, written incident response plan, and enhanced service provider oversight.

Action: Confirm your incident response plan documents a 30-day notification timeline.

SEC FY2025 Enforcement: 20-Year Low in Actions

456 enforcement actions — the lowest in 20 years. Actual monetary relief approximately $2.7B. Crypto enforcement narrowed to target only clear fraud.

Action: Expect more scrutiny of intent and causation, not just transaction volume.

OCC GENIUS Act Stablecoin NPRM — Comments Close May 1

Requirements for OCC-licensed payment stablecoin issuers: application/governance, reserve/redemption obligations, prohibition on interest/yield-bearing features.

Action: Submit comments now if you issue or plan to issue stablecoins.

DORA Active Supervision: EU's First Full Year

The Digital Operational Resilience Act enters its first full year of active supervisory enforcement. Regulators are testing ICT risk management, incident reporting, and third-party dependencies.

Action: Audit your ICT risk register against DORA expectations.


One Thing to Do Today

Block time this weekend for your FinCEN comment letter. June 9 is 45 days away. Reading the NPRM and preparing 2-3 substantive comment points takes 4-6 hours.

Next Week: Cybersecurity + Data Security + Cloud Security — Vulnerability management, incident response, and critical cloud infrastructure oversight.

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Actionable Regulatory Intelligence

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