The Evidence Gap Index
How the major AML/CFT program-rule letters answer the question none of them asked.
Compiled by Sviatoslav Zhuravlev · notary/cloud · 2026-06-12 · download as PDF
The comment period on FinCEN's AML/CFT program-rule docket closed on June 9, 2026, with 112 comments filed; the parallel agencies' docket, OCC-2024-0005, holds 41 more. Banks, associations, and vendors will be parsing these letters until the final rule. This index maps the major ones.
It is a reading of the load-bearing letters, not a census: we did not read all the filings on both dockets. What we read, we scored on a 0-5 evidence-proximity scale, and each score links to the public letter on regulations.gov - check our reading in one click. One comment ID is still being confirmed; its row says so.
Nearly every industry letter on FINCEN-2026-0034 and the parallel agencies' docket OCC-2024-0005 asks regulators to defer to documented risk-based decisions. This index measures how close each letter comes to the question underneath that ask: what makes the documentation itself trustworthy as evidence at examination time, years later, after the systems that produced it have changed.
Scoring rules: a letter earns a level only if it engages that layer explicitly; flattering inference is not allowed - including for letters whose authors we like. One illustrative paraphrase per letter; no verbatim quotes over 15 words; one quote max per source.
Counting caveat: several letters (the BPI and The Clearing House joint letter among them) were filed to both dockets, so the per-docket counts double-count cross-filers. The OCC docket also spans two comment rounds (2024 and 2026).
† Unit21: Reviewed from the public docket; the regulations.gov comment ID is pending confirmation, so this row carries no source link yet.
The docket tops out at level 3. In the major industry letters reviewed for this index - the ones banks, associations, and vendors themselves treat as load-bearing - and in our scan of the docket's late wave, no letter reaches level 4 or 5: none asks who can verify a documented decision, and none proposes a mechanism by which the record remains verifiable after the models, vendors, and log systems that produced it have been replaced. We have not read all filings on both dockets (112 + 41, with cross-filers double-counted); we read the ones the industry put its weight behind. That is the open question the docket states by omission.
The index as a PDF, no email required: evidence-gap-index-2026-06-12.pdf. Leave an email if you want one update when the final rule drops - that is the whole list.
Notary Cloud builds externally verifiable records for AI decisions in regulated workflows.
Compiled by Sviatoslav Zhuravlev · published 2026-06-12 · scores reflect our reading; the letters are linked - check us. Corrections: [email protected]