The Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) to strengthen and modernize financial institutions’ anti-money laundering and countering the financing of terrorism (AML/CFT) programs. While financial institutions have long maintained AML/CFT programs under existing regulations, this proposed rule (or “AML/CFT Program NPRM”) would amend those regulations to expressly require that such programs be effective, risk-based, and reasonably designed, enabling financial institutions to focus their resources and attention in a manner consistent with their risk profiles.