FinCEN’s AML Program Rule Overhaul, Stablecoins, and the 10-Year Legacy of the Panama Papers

In this week’s This Week in AML, Elliot Berman and John Byrne break down FinCEN’s newly released notice of proposed rulemaking to modernize the AML/CFT program rule—its first major rethink in two decades. They explore what a risk-based refocus could mean in practice, including new requirements for risk assessments, changes to the four pillars, examiner discretion, and the unprecedented requirement that bank regulators consult with FinCEN before certain enforcement actions. The conversation also covers a flurry of regulatory and enforcement developments: the OCC’s GENIUS Act proposal on stablecoins, the removal of reputation risk from bank examinations, and what both could mean for smaller financial institutions. Elliot and John look back at the 10-year anniversary of the Panama Papers, review the FBI’s 2025 Internet Crime Report, and discuss global enforcement challenges—from scam centers in Southeast Asia to resource constraints at foreign FIUs.