Notabene Response to FinCEN AML/CFT Program NPRM

Notabene filed its response to FinCEN’s AML/CFT Program NPRM, Docket FINCEN-2026-0034, supporting a risk-based, outcomes-focused framework for modern financial institutions.

The response recommends that FinCEN define AML/CFT program effectiveness by the outcomes a program achieves, including risk mitigation, BSA compliance, and the production of highly useful information for government authorities.

For digital asset MSBs, Notabene encourages FinCEN to recognize Travel Rule infrastructure, pre-transaction authorization, IVMS 101 data standardization, and counterparty due diligence interoperability as innovative compliance activities that produce demonstrable supervisory and enforcement outputs.