BPI and The Clearing House Association Comment on Federal Reserve AML/CFT Program Proposal

Ladies and Gentlemen:

The Bank Policy Institute^[1] and The Clearing House Association^[2] are writing to comment on the notice of proposed rulemaking to "ensure that Board-supervised banks establish and maintain effective AML/CFT programs that better achieve the purposes of the Bank Secrecy Act" by providing "highly useful information related to illicit financial transactions for law enforcement and national security agencies."^[3]

We appreciate the Board's willingness to join in significant part in the related rulemaking efforts of FinCEN, the OCC, the FDIC, and the NCUA (collectively, the "agencies") to implement the reforms to the AML/CFT program obligations that Congress has mandated and that the U.S. financial system desperately needs. The Board's proposed rule is generally consistent with the proposals from FinCEN and the other agencies, including an explicit mandate for banks to "direct more attention and resources toward higher-risk customers and activities, consistent with the risk profile of the bank, rather than toward lower-risk customers and activities."^[4]

To read the full comment letter, please click here, or click on the download button below.

[1] The Bank Policy Institute ("BPI") is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

[2] The Clearing House Association L.L.C., the country's oldest banking trade association, is a nonpartisan organization that provides informed advocacy and thought leadership on critical payments-related issues. Its sister company, The Clearing House Payments Company L.L.C., owns and operates core payments system infrastructure in the United States, clearing and settling more than $2 trillion every business day.

[3] Bd. of Governors of the Fed. Rsrv. Sys., Anti-Money Laundering and Countering the Financing of Terrorism Programs, 91 Fed. Reg. 42,363 (July 9, 2026) (the "NPRM"), https://www.federalregister.gov/documents/2026/07/09/2026-13919/anti-money-laundering-and-countering-the-financing-of-terrorism-programs#h-80.

[4] Id. at 42,366.