By Lionel J. Perez ( September 23, 2026, 11:28 AM EDT) -- Since March 26, 2026, every reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act must under the new s. 9.6(1.1) “ensure that the program is reasonably designed, risk-based and effective.” Its schedule entry is a very serious violation with a $20 million per violation ceiling for an entity ($4 million for a person). Little has been written about what s. 9.6(1.1) actually adds: an express program-level performance standard....