6/9/26
ICBA Comment Letter - Joint Agencies Proposed AML-CFT Program Rule (June 2026)
ICBA supports a risk-based, effectiveness-oriented framework that better targets illicit finance risk while preserving flexibility for community banks. For community banks, however, the success of this framework will depend on whether the final rule recognizes the operational realities of smaller, relationship-based institutions and avoids layering on expectations better suited to large, complex organizations.