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Welcome to the September 2025 summary of news you can use as your bank or other financial institution attempts to stay up to date on the world of BSA/AML compliance. Our monthly series of curated news about FinCrime regulatory developments, resources and stories.
In this edition, two main stories emerge:
- FinCEN prepares rulemakings to implement GENIUS Act requirements for permitted payment stablecoin issuers
- Treasury to overhaul AML/CFT program requirements to focus on better outcomes
FinCen prepares rulemakings to implement GENIUS Act requirements for permitted payment stablecoin issuers
On September 9, 2025, FinCEN Director Andrea Gacki testified before the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions, regarding FinCEN’s ongoing efforts to combat illicit finance and modernize AML requirements.
As part of Gacki’s presentation, she stated that FinCEN is preparing rulemakings to implement the GENIUS Act’s requirements, including those that apply BSA obligations to permitted payment stablecoin issuers. The act states that these issuers must:
- Establish and maintain comprehensive anti-money laundering (AML) and counter-terrorist financing (CTF) programs
- Implement an effective customer identification (CIP) program for initial holders of their payment stablecoins
- Monitor transactions for suspicious activity and report them as required by the BSA
- Implement an effective sanctions compliance program
- Have the technological and procedural capabilities to block, freeze, and reject illicit transactions
- Maintain appropriate records of transactions to facilitate BSA compliance
- Train compliance staff on BSA and AML requirements
Gacki also highlighted FinCEN’s recent request for comment on “innovative methods, techniques, and strategies” to detect illicit digital asset activity, including the use of AI and blockchain monitoring.
Read more here:
Treasury to overhaul AML/CFT program requirements to focus on better outcomes
Speaking at the ACAMS Las Vegas Conference, John K. Hurley, Treasury’s Under Secretary for Terrorism and Financial Intelligence stated that AML/CFT programs should deliver better outcomes by providing law enforcement and the national security establishment with the most useful information, not by overwhelming the system with noise. By “noise”, Hurley was referring to the vast amount of reporting which financial institutions currently perform but that do not make AML/CFT more effective.
To achieve a more outcomes-focused paradigm, Hurley said that treasury intends to replace subjective assessments of process with objective measures of output. “The best measures of the effectiveness of program are not how it looks, but first and foremost, how well it captures and proactively reports what law enforcement needs, and secondly, how rarely it fails to identify activity it should be capturing, especially when that activity utilizes known typologies,” said Hurley.
Hurley also highlighted the need to leverage AI and other advanced technologies to make AML/CFT programs more effective. In fact, he refers to well-governed technology as a “force multiplier.” His view is that financial institutions that use AI to reduce or eliminate false positives while escalating truly vital information to law enforcement more rapidly “should be celebrated, not written up.”
Read more here:
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