FinCEN AML/CFT Overhaul: Key Changes for Banks
June 10, 2026
FinCEN’s April 7 proposed rule overhauling the Bank Secrecy Act and AML/CFT program requirements across all financial institutions — not just banks — continued to
When you build financial products, you’re navigating licensing hurdles, bank partners, compliance reviews, engineering timelines, and regulators who move slower than your roadmap, so you don’t need theory. You need counsel that keeps pace with you without missing a single regulatory trigger. We’re here to help you scale fast, stay compliant, and avoid surprises that stall momentum.
because we advise fintechs, payments companies, and embedded finance operators across the U.S.
in Texas and Idaho, and we support fintech models operating nationwide.
supported high-growth platforms handling payments, money transmission, deposits, lending, and complex multi-state operations.
When you need fast, seasoned counsel, you’ll get it.
We interpret federal and state requirements across payments, lending, money transmission, and consumer protection so your team can build with certainty. You get practical guidance that keeps launches on track and regulators satisfied.
From embedded payments to new lending products, we help you design offerings that align with licensing rules and partner expectations. You get clear guardrails that protect innovation rather than slow it down.
We structure and negotiate BaaS and sponsor-bank relationships that withstand examiner scrutiny. You’ll scale with confidence and without creating the kind of risk that invites regulatory headaches.
Disputes, chargebacks, fraud claims, and account escalations require fast, defensible action. We help you assess liability, document the response, and coordinate with partner banks when required.
APIs, processors, distributors, and service providers all require contracts that protect the platform. We draft and negotiate agreements that create clarity, reduce exposure, and support long-term scalability.
For fintech lenders, capital providers, and hybrid models, we assist with structuring, documentation, and compliance considerations. Your team gets clean, compliant lending frameworks that hold up under regulatory review.
Whether you’re raising capital, restructuring, or planning for long-term growth, we help you build a corporate framework that aligns with regulatory expectations and investor requirements.
Founders and operators need structure that supports investment, control, and scalability. We establish clear ownership and governance foundations that prevent downstream disputes and complexities.
Your compensation structures must attract talent and satisfy tax, investor, and regulatory considerations. We design incentive plans that align key contributors without unexpected consequences.
Whether you’re acquiring technology, selling a book of business, or relocating operations, we support strategy, diligence, and negotiation. You’ll understand the risks long before term sheets hit your desk.
We help you secure tax credits, incentives, and specialized programs that support expansion and innovation. From federal tools to state-level incentives, we surface opportunities others overlook.
Big-firm horsepower. Boutique responsiveness. No “please hold.”
You get direct access, fast answers, and guidance written for operators, not theorists. When pressure builds, we help you navigate banks, regulators, auditors, and partners with clarity and strategy.
When you need to protect the platform, respond quickly, or steady a regulator or partner, we’re the call you make.
We assess your model, outline your regulatory obligations, and map the cleanest path forward.
We help you negotiate expectations, define scope, and avoid unnecessary friction that slows your product down.
We guide you through allocation, documentation, and recovery based on your model and contracts.
We predict compliance requirements and review, refine, and structure your program so you can release with confidence.
We support your board and executive team with policy mapping, safety-and-soundness alignment, risk assessments, partner-bank expectations, and remediation planning. The result: oversight that withstands regulatory and partner scrutiny.
Stay ahead with plain-English updates that turn complex rules into simple operational steps.
FinCEN’s April 7 proposed rule overhauling the Bank Secrecy Act and AML/CFT program requirements across all financial institutions — not just banks — continued to
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You focus on building the future of finance. We’ll help you stay compliant, nimble, and ready for whatever your regulator, bank partner, or customer throws at you next.