• Earlier this month, the Trump administration released its 2026 regulatory agenda, including upcoming financial crime and related rulemakings identified by the U.S. Treasury Department.
• The Treasury Department agenda lists rulemakings pertaining to beneficial ownership and the outbound investment security program, but it does not include much-awaited changes to the anti-money laundering program rule for investment advisers.

This has already been an active year for rulemakings and regulatory guidance related to combatting financial crime. For example, earlier this year, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) and the federal banking agencies issued important proposals to revise financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) program requirements; to establish AML/CFT, customer identification program (“CIP”) and sanctions compliance requirements for payment stablecoin issuers; and to implement a whistleblower program for reporting Bank Secrecy Act (“BSA”), sanctions and other violations.

Earlier this month, the White House Office of Management and Budget (“OMB”) released the government-wide 2026 Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions (the “Agenda”).^[1] As part of the Agenda, the Treasury Department provided an updated roadmap for its active and anticipated rulemakings, including those involving FinCEN.

The FinCEN and other items on Treasury’s list are instructive as to the Trump administration’s priorities with respect to financial crime and related matters for the balance of this year and beyond. We list below the financial crime items identified by Treasury for the Agenda, along with the sole Agenda item related to the outbound investment security program, which is the anticipated rulemaking mandated by the Comprehensive Outbound Investment National Security (“COINS”) Act. We have noted the timing attached to each action item or noted where none is supplied.

A few items of note:

• Beneficial ownership reporting/identification. Item 1 above indicates that Treasury intends to finalize the rule implementing its narrowed approach to beneficial ownership information reporting under the Corporate Transparency Act (the “CTA”). The final rule cleared OMB review on July 16, 2026, which signals it may be released imminently.

  Item 7 above indicates that FinCEN intends to issue proposed revisions to the current beneficial ownership identification and verification requirements for financial institutions under the customer due diligence (“CDD”) rule, as called for by the CTA.^[2] It will be interesting to see how FinCEN proposes to revise CDD requirements, given that the CTA envisions much broader beneficial ownership information reporting to FinCEN as the basis for a revised set of CDD requirements.

• AML/CFT requirements for investment advisers. The long-anticipated revision to the AML/CFT program rule for investment advisers is conspicuous for its absence from the list. At the outset of the second Trump administration, Treasury delayed the effective date of the final investment adviser AML/CFT program rule to January 1, 2028, and signaled substantive revisions to that rule would be forthcoming. The Agenda provides no indication of Treasury’s plans.

  Item 3 above indicates that Treasury intends to issue, along with the Securities and Exchange Commission (the “SEC”), a proposed rule to replace the Biden administration proposal regarding CIP requirements for investment advisers. The Treasury listing states that the requirements in the reissued proposal should “be more effectively tailored to the diverse business models and risk profiles of types of firms within the investment adviser sector than in the originally proposed rule.” Interestingly, although Treasury identifies its timeline for the joint proposal as September 2026, the SEC does not forecast issuing an NPRM until July 2027.^[3]

• BSA modernization. Treasury also has indicated that FinCEN may propose or finalize various technical and other regulatory amendments in conjunction with ongoing efforts to modernize BSA reporting thresholds and processes, citing sections 6204 and 6205 of the Anti-Money Laundering Act of 2020 (the “AML Act”).^[4] Those sections relate to suspicious activity and currency transaction reporting, including review of potential adjustments to thresholds. Treasury also references the comprehensive review of existing regulations to enhance regulatory efficiency required by section 6216 of the AML Act and has recently emphasized the importance of BSA modernization to protecting the U.S. financial system against illicit finance threats.^[5] However, Treasury did not include in the Agenda any regulatory actions to address these AML Act provisions.

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