On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) issued the first government-wide priorities for anti-money laundering and countering the financing of terrorism (AML/CFT) policy (i.e., the “Priorities”). These were required as part of the AML Act of 2020; FinCEN now has 180 days to establish regulations regarding these Priorities.
This issuance identifies and describes the most significant AML/CFT threats and provides informational resources to help assess and manage risk, tailor AML programs, and prioritize resources.
The Priorities include:
- Cybercrime (including cybersecurity and virtual currency considerations);
- Domestic and foreign terrorist financing;
- Transnational criminal organization activity
- Drug trafficking;
- Human trafficking and human smuggling, and,
- Proliferation financing.
Covered institutions are not required to make any immediate changes to their risk-based AML programs in response to these Priorities and may wait until FinCEN issues regulations. That said, you might want to at least start thinking about how you might incorporate these into your AML program.
Stay tuned! We will address this further in our August edition of Banking on BCC.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!