On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “FinCEN NPRM”) to reform anti-money laundering and countering the financing of terrorism (“AML/CFT”) program requirements under the Bank Secrecy Act (“BSA”) for all regulated financial institutions. In a parallel Notice of Proposed Rulemaking…