FinCEN announced this proposal on June 28, 2024 and published it in the Federal Register on July 3, 2024, with comments due September 3, 2024. It would have required 'effective, risk-based, and reasonably designed' AML/CFT programs and encouraged institutions to responsibly adopt innovative technologies including machine learning, generative artificial intelligence, digital identity tools, blockchain analytics, and APIs, stating that experimenting with them would not by itself create supervisory or enforcement risk. FinCEN withdrew the proposal in April 2026 and superseded it with a new AML/CFT program NPRM.
| Document | 2024 AML/CFT Program Proposed Rule (withdrawn) — Anti-Money Laundering and Countering the Financing of Terrorism Programs (Notice of Proposed Rulemaking, 2024) |
| Issued by | Financial Crimes Enforcement Network |
| Type | Consultation |
| Status | Withdrawn |
| Published | Jul 3, 2024 |
| Comment deadline | Sep 3, 2024 |
| Applies to | All financial institutions with AML/CFT program obligations under the Bank Secrecy Act |
| Superseded by | 2026 AML/CFT Program Proposed Rule |
| Official source | federalregister.gov ↗ |
| Use cases | AML / KYC · Generative & agentic AI · AI governance (general) |
What are the key points of 2024 AML/CFT Program Proposed Rule (withdrawn)?
- Announced June 28, 2024; Federal Register publication July 3, 2024; comment deadline September 3, 2024
- Implemented section 6101 of the AML Act: programs must be effective, risk-based, and reasonably designed, with a mandatory risk assessment process incorporating the AML/CFT Priorities
- Expressly encouraged responsible adoption of machine learning, generative AI, digital identity, blockchain analytics, and APIs as part of internal policies, procedures, and controls
- Stated that institutions experimenting with innovative technologies will not face additional supervisory or enforcement risk solely because of the experimentation
- Issued with an interagency statement from the OCC, Federal Reserve, FDIC, and NCUA, which proposed parallel amendments to their bank program rules on July 19, 2024
- Never finalized; FinCEN's April 7, 2026 press release says the 2026 proposal 'fully supersedes' the July 3, 2024 proposal and that FinCEN is withdrawing it
What did 2024 AML/CFT Program Proposed Rule (withdrawn) change for banks?
This was the first time FinCEN put generative AI by name into a proposed regulation and offered a written assurance that piloting it in AML would not itself be an enforcement risk. Although withdrawn, its innovation language carried into the 2026 proposal, and its comment file documents industry positions on AI in AML.
Was the July 2024 FinCEN AML/CFT program rule ever finalized?
No. FinCEN withdrew it in April 2026 and replaced it with a new proposed rule published April 10, 2026.
Did the 2024 proposal require AI adoption?
No. It encouraged responsible adoption of machine learning and generative AI and promised no added enforcement risk for experimentation, but left technology choices to each institution.
| Date | Document | Status |
|---|---|---|
| Apr 10, 2026 | 2026 AML/CFT Program Proposed Rule — Anti-Money Laundering and Countering the Financing of Terrorism Programs (Notice of Proposed Rulemaking, 2026) | Proposed |
| Jul 24, 2026 | FIN-2026-Alert004 (Federal Student Aid Fraud) — FinCEN Alert on Fraud Schemes Targeting Federal Student Aid | In force |
| Nov 13, 2024 | FIN-2024-Alert004 (Deepfake Media) — FinCEN Alert on Fraud Schemes Involving Deepfake Media Targeting Financial Institutions | In force |
| Apr 9, 2021 | 2021 BSA/AML Model Risk Management Statement — Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance | Withdrawn |
| Jan 1, 2021 | Anti-Money Laundering Act of 2020 — Anti-Money Laundering Act of 2020 (Division F of the National Defense Authorization Act for Fiscal Year 2021) | In force |
| May 1, 2019 | FinCEN Innovation Hours — FinCEN's Innovation Initiative: Implementation of FinCEN Innovation Hours; Invitation to Request Innovation Hours Meeting | In force |
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