Letters to FinCEN, OFAC, and federal banking agencies emphasize the need for operational flexibility, consistent supervisory expectations, and responsible adoption of innovative compliance technologies

Washington, DC (June 10, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted comment letters to the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), and federal banking agencies regarding proposed rulemakings on Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) and sanctions compliance programs. The letters underscore the importance of shifting toward an outcomes-oriented and risk-based compliance framework that mitigates illicit finance threats without imposing rigid or duplicative procedural burdens.

“Modernizing our nation's AML/CFT and sanctions frameworks is critical to safeguarding the financial ecosystem from illicit activity while fostering responsible innovation,” said Phil Goldfeder, CEO of the American Fintech Council. “Regulators must establish clear, predictable, and collaborative compliance standards that embrace innovative tools rather than relying on outdated, manual, and procedural requirements that increase costs without improving outcomes.”

In its letter to FinCEN regarding proposed AML/CFT program requirements, AFC supported the agency’s efforts to adopt a more outcomes-oriented supervisory framework focused on effectiveness rather than procedural formalism. AFC also emphasized the importance of preserving flexibility for institutions to tailor compliance programs to their risk profiles and leverage emerging compliance technologies.

In a separate letter to federal banking agencies, AFC highlighted the need for supervisory consistency, reduced duplication, and greater integration of AML/CFT requirements within existing compliance frameworks. AFC noted that clearer alignment across regulators would help reduce unnecessary compliance burdens, improve efficiency, and allow institutions to focus resources on higher-risk areas.

“Effective AML/CFT supervision should focus on identifying and mitigating meaningful risks rather than measuring compliance through procedural checklists,” said Ian P. Moloney, Chief Policy Officer of the American Fintech Council. “A risk-based framework gives institutions the flexibility to deploy resources where they can have the greatest impact while strengthening the information and tools available to regulators and law enforcement.”

In a letter to FinCEN and OFAC, AFC addressed proposed AML/CFT and sanctions requirements for payment stablecoin issuers under the GENIUS Act. AFC advocated for clear regulatory boundaries, practical compliance expectations, and a framework that reflects the unique structure of blockchain-based payment systems while maintaining strong protections against illicit finance.

A standards-based organization, the American Fintech Council (AFC) is the largest and most diverse trade association representing financial technology (fintech) companies and innovative banks. On behalf of over 150 member companies and partners, AFC promotes a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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