FinCEN Seeks Comments on Potential Changes to AML Program Requirements
The Financial Crimes Enforcement Network (FinCEN) recently published a notice seeking public comment on potential regulatory changes that would require all financial institutions subject to anti-money laundering (AML) programs to ensure such programs are effective and reasonably designed.
Under the changes, an effective and reasonably designed program would:
- Identify, assess and mitigate AML risks consistent with the institution’s risk profile and national AML priorities;
- Comply with the Bank Secrecy Act’s recordkeeping and reporting requirements; and
- Provide information with a high degree of usefulness to government authorities.
There also is a proposal for FinCEN to issue a list of national AML priorities every two years, referred to as the Strategic Anti-Money Laundering Priorities.
These changes are intended to improve national risk management and mitigation efforts by defining what an effective and reasonably designed AML program is, and allowing financial institutions to reallocate resources between high and low priority risks.
Interested parties may submit comments here on or before November 16, 2020.
