WASHINGTON, DC (June 10, 2026) |
The Defense Credit Union Council (DCUC) has submitted formal comments to the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the National Credit Union Administration (NCUA) in response to a proposed rule implementing provisions of the Anti-Money Laundering Act of 2020 (AML Act) and modernizing AML/CFT program requirements. The proposal was developed in coordination with the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and FinCEN.
“DCUC generally supports the proposal’s transition toward risk-based, effective AML/CFT programs. We believe the proposal appropriately emphasizes risk-based supervision, program effectiveness, and institution-specific risk management. As the agencies finalize the rule, we encourage NCUA to preserve flexibility for credit unions, promote consistent examination practices, and avoid unnecessary compliance burdens that do not enhance the effectiveness of AML/CFT programs,” wrote Jason Stverak, DCUC Chief Advocacy Officer.
In its letter, DCUC strongly supported the proposal’s emphasis on tailoring AML/CFT programs to the size, complexity, and risk profile of individual institutions. Stverak noted that credit unions should not be held to one-size-fits-all standards that may not reflect their operational realities.
Stverak recommended that regulatory expectations should remain flexible, allowing institutions to apply appropriate methodologies for risk assessment, documentation, and ongoing program maintenance without unnecessary administrative burden.
DCUC’s letter also noted the importance of consistent examiner training and implementation across regions to ensure the effectiveness of a risk-based framework. Stverak encouraged enhanced guidance and training to examiners to ensure alignment in supervisory expectations and application.
“A risk-focused examination framework allows supervisory resources to be directed toward the most significant concerns while reducing unnecessary burden on smaller institutions that maintain effective compliance programs. Consistency in examiner expectations and adequate training will be essential to the successful implementation of this rule,” says Stverak. “It’s important to recognize the unique operational environment of credit unions serving military communities, including deployed servicemembers and highly mobile families, when applying supervisory standards.
DCUC expressed support for the proposal’s recognition of innovative technologies that can strengthen AML/CFT compliance efforts, while cautioning against expectations that institutions adopt specific tools or systems regardless of size or capacity.
“We encourage regulators to allow sufficient time for implementation, and recommend an 18–24 month compliance period following publication of the final rule, along with continued industry engagement, training webinars, and coordinated guidance across federal regulators,” adds Stverak.