Compliance Weekly Notes
Apr 20 – Apr 26 · 2026-W17
1 event this week
🏛️ FinCEN reform analysis week Compliance
⚡⚡ Oil peaks + earnings warning Markets
🔄 Quiet week Data Engineering
🧠 Feynman Takeaway
BakerHostetler analyzed FinCEN's proposed rule: shift from 'checking boxes' to 'demonstrating results.'
FinCEN Reform Analysis: 'Results, Not Paper'
In plain English
BakerHostetler published a detailed analysis of FinCEN's proposed AML/CFT program rule. The key insight: the rule shifts AML supervision from checking whether compliance boxes are ticked to evaluating whether the program actually prevents money laundering. 'Results, not paper.'
Analogy
Imagine a school that used to grade teachers on whether they took attendance and followed the lesson plan. The new system grades them on whether students actually learned. That's effectiveness-based supervision.
Why it matters
This shift was profound. It meant compliance officers could stop pretending every customer was equally risky and focus on the genuine threats. It also meant more discretion — and more responsibility.