The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed regulations to remove the anti-money laundering program exemption for banks that lack a federal functional regulator, including, but not limited to, private banks, non-federally insured credit unions, and certain trust companies.  The proposed regulations would require banks that lack a federal functional regulator to implement anti-money laundering programs and would extend customer identification program requirements and beneficial ownership requirements to those banks not already subject to these requirements.