2026 Mid-Year Anti-Money Laundering Regulatory and Enforcement Update
Financial institutions and compliance teams must revise AML programs to address 2026 mid-year enforcement actions, new fraud information-sharing guidance, and proposed federal centralization of AML supervision.
Gibson Dunn’s mid-year 2026 AML update outlines significant regulatory and enforcement shifts across five core areas. Key developments include a $9.7 million non-prosecution agreement for EagleBank tied to willful AML program failures that enabled a years-long check-kiting scheme, FinCEN’s record $80 million civil penalty against broker-dealer Canaccord Genuity for under-resourced AML controls, and DOJ subpoenas to major banks investigating alleged politically motivated “debanking.” The Trump administration also issued new FinCEN guidance clarifying fraud qualifies as a predicate offense for voluntary 314(b) inter-institution information sharing, and proposed rules to centralize AML supervision and enforcement across federal agencies. In-house counsel for financial institutions should audit existing AML/CFT programs, update fraud detection and information-sharing protocols, and track pending centralization rulemaking to mitigate compliance risk.