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.

Statements on the AML/CFT Priorities were also issued for banks and non-bank financial institutions to provide guidance on how to approach the 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:

  1. Corruption;
  2. Cybercrime (including cybersecurity and virtual currency considerations);
  3. Domestic and foreign terrorist financing;
  4. Fraud;
  5. Transnational criminal organization activity
  6. Drug trafficking;
  7. Human trafficking and human smuggling, and,
  8. 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.


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