FinCEN Targets Fraud and Advances BSA Modernisation Agenda

Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), used written testimony before the US House of Representatives Committee on Financial Services on 21 July 2026 to set out two priorities that will resonate with UK compliance practitioners: disrupting the fraud that generates the largest share of illicit proceeds, and rebuilding the Bank Secrecy Act (BSA) framework around effectiveness rather than technical compliance.

On fraud, FinCEN pointed to measurable recoveries. Its Rapid Response Program (RRP), run with US and foreign law enforcement, has facilitated the interdiction of nearly $2 billion in stolen proceeds for 5,790 US individuals and businesses since 2015. The agency also confirmed that it severed the Huione Group, linked to the laundering of at least $4 billion, from the US financial system in October 2025, with follow-on action last month against successor entities attempting to circumvent that cut-off. For UK institutions, the durability of that laundering infrastructure matters more than its US nexus: correspondent relationships, payment intermediaries and marketplace platforms that survive a first designation frequently resurface under new names, and screening logic keyed only to the original entity will miss the reconstituted network.

Gacki also highlighted work supporting the White House Task Force to Eliminate Fraud, including typologies for organised crime and transnational criminal organisations targeting government healthcare and benefit programmes, alongside guidance clarifying how financial institutions can share fraud information with one another in real time. This is the strand with the clearest read-across for UK firms. The direct information-sharing gateway and the corporate offence of failure to prevent fraud, both introduced under the Economic Crime and Corporate Transparency Act 2023, place a comparable premium on collaborative detection and on demonstrable, reasonable procedures rather than box-ticking. The parallel operationalisation of FinCEN's whistleblower programme, now triaging incoming tips ahead of a final award rule, is a further reminder that fraud intelligence increasingly arrives from outside the regulated perimeter.

The modernisation agenda is where UK observers will find the most instructive material. FinCEN's Suspicious Activity Report (SAR) Frequently Asked Questions, issued last October, aim to concentrate reporting on information of genuine value to law enforcement rather than defensive volume. The proposed Program Rule issued in April goes further, refocusing anti-money laundering and countering the financing of terrorism (AML/CFT) programmes on effectiveness and introducing a new supervisory role for FinCEN to promote risk-based, reasonably designed programmes and greater consistency in how banks are assessed. That is the same effectiveness-versus-technical-compliance debate that has shaped the UK Financial Conduct Authority's (FCA) supervisory expectations and the Money Laundering Regulations reform discussion, and firms operating across both jurisdictions should expect scrutiny to converge on outcomes, not artefacts.

Finally, FinCEN issued two proposed rules implementing AML and customer identification requirements for permitted payment stablecoin issuers under the GENIUS Act. The timing is notable: the UK is standing up its own two-tier regime, with the FCA regulating qualifying stablecoins and the Bank of England taking prudential oversight of systemic tokens. Practitioners advising issuers or the institutions that bank them will need to reconcile two maturing rulebooks whose AML expectations are being written in parallel.

Read the statement here.