FinCEN's Advance Notice of Proposed Rulemaking: How Financial Institutions Can Enhance AML Programs and Prepare for Changes Ahead
The regulatory amendments under consideration are intended to upgrade and modernize the national AML regime, where appropriate, to address the evolving threats of illicit finance, and to provide financial institutions with greater flexibility in the allocation of resources to enhance the effectiveness and efficiency of their AML programs.
December 30, 2020 at 12:45 PM
7 minute read
On Sept. 16, 2020, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (ANPRM) to strengthen the national anti-money laundering (AML) regime, as part of a collaboration with law enforcement and members of the financial industry.
The regulatory amendments under consideration are intended to upgrade and modernize the national AML regime, where appropriate, to address the evolving threats of illicit finance, and to provide financial institutions with greater flexibility in the allocation of resources to enhance the effectiveness and efficiency of their AML programs. The potential amendments also aim to facilitate the ability of the financial industry and corresponding supervisory authorities to leverage new technologies and risk management techniques, share information, discard inefficient and unnecessary practices, and focus resources on fulfilling the stated purpose of the Bank Secrecy Act (BSA) to provide information with a high degree of usefulness to government authorities. Written comments on the ANPRM were due within 60 days.
In order for financial institutions to assess and prepare for potential changes ahead, they need to understand the specific measures proposed for enhancing the national AML regime. The proposed amendments have several key components:
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